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Gap Analysis Kona International Airport at Keahole (KOA) Safety Management System Submitted to: Sta te of Hawaii Department of Transportation Airports Division Submitted by: Jacobs Consultancy Final Report - June 2008

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Gap Analysis

Kona International Airport at Keahole (KOA)

Safety Management System

Submitted to

Sta te of Hawaii Department of Transportation Airports Division

Submitted by

Jacobs Consultancy

Final Report - June 2008

Gap AnalysisKona International Airport at Keahole Safety Management System

Table of Cont ents

Section Page

EXECUTIVE SUMMARY i

I IN TRODUCTION 1 Background 1 Objectives 1 Methodology Oper ations at KOA 2 Struct ure of TheGap Analysis 3

II SAFETY P OLICIES AN D OBJECTIVES 6 Key Features 6 Existing Policies And Object ives 6 Gaps and Development Required 7

III SAFETY ORGAN IZATION 9 Key Features 9 Existing Policies Pr actices and Sy stem s 10 Gaps and Development Required 16

IV SAFETY R ISK MAN AGEMENT 19 Key Features 19 Existing Pract icesand Syst ems 19 Gaps and Development Required 19

V SAFETY ASSURANCE 21 Key Features 21 Existing Pract icesAnd Syst ems 22 Gaps and Development Required 24

VI SAFETY PR OMOTION - TRAININ G 25 Key Features 25 Existing Policies Pr actices and Sy stem s 25 Gaps and Development Required 26

VII SAFETY PR OMOTION - COMMUNICATION S 27 Key Features 27 Existing Policies Pr actices and Sy stem s 27 Gaps and Development Required 27

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Dele ted 2

Dele ted 2 0

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Dele ted 2 0

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Dele ted 2 0

Dele ted 1 9

Dele ted 2 2

Dele ted 2 1

Dele ted 2 2

Dele ted 2 1

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Dele ted 2 2

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Dele ted 2 9

Dele ted 2 8

LIST OF APPENDICES

Appendix A Draft St atem ent Of Wor k - FAA SMS Airpor t Pilot Study

Appendix B Saf ety Issues

Appendix C Inspection Checklists

Appendix D Exam ples of Saf ety and Sec ur it y Enforcem ent Programs

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EXECU TIVE SUMMA RY

In Februar y 2007 the FAA issued Advisory Circular AC 1505200-37 Int roduction to Safety Managem ent Systems (SMS) for Airport Operator s to int roduce the concepts of SMS The FAA also init iated a pilot program to assist airports in the development of an SMS specific t o their s it uation and oper ations and to shar e their acquired experience on SMS development and implem entation with other airports and the FAA

The Hawaii Depar tment of Tr ansport ation Air por ts Divis ion (HDOT-A) has dec ided to take a leadership r ole in the development and im plem entation of SMS at the Kona Internat ional Air port at Keahole (KOA) by part icipating in the FAA pilot program

The purpose of this docum ent is t o provide aGap Analysis to ident ify procedur es policies docum entation and act ions that HDOT-A and KOA need to implement as part of its SMS that go beyond the c urrent FARs Part 139 requirem ents The Gap Analysis out lines SMS requirements and com pares them with Part 139 requir ements

As detai led in t his report the gaps between exist ing requir ements and the FAArsquos anticipated SMS r egulat ions and guidance mat erial are as fol lows

Safety Policies and Objectives

Specific aviation saf ety policies and objectives need to be developed for inclusion in the SMS The Gap Analys is outlines key fact ors t hat should be consider ed in Safety Objectives and t hat will be further elabor ated in the SMS Manual

Safety Organization

HDOT-A and KOA do not have an or ganizat ional structur e defined specific ally for addr essing the requirement s of an SMS including the role of top management The Gap Analys is detai ls the pot ential safety or ganization for consideration f or the SMS Manual including the role of the Dist rict Engineer in conducting safety risk management assessments( operational risk assessm ents) for projects

Safety Risk Management

KOA current ly does not have a formal Saf ety Risk Management ( SRM) processf or aviation saf ety The SRM process will be d eveloped and documented during Phase 2

Safety Assurance

Phase 2 will dev elop

o Non-punitive reporting

o System atic reviews and audits

o Safety over sight

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Safety Training and Communication

Gaps include

o SMS training

o Av iat ion safet y pr ograms

Phase 2 will dev elop the SMS based on the gaps identif ied

During the Gap Analysis J acobs Consultancy also made a num ber of observations on existing prac tic es and policies curr ently required under FARs Part 139 Not necessar ily part of an SMS these observations for considerat ion by KOA and HDOT-A are as follows

The HDOT-A should consider making the wearing of safety vests mandatory for all personnel working on the AOA

HDOT-A should consider am ore structured Enfor cement Progr am for specif ied airsid e safety violat ions

HDOT-A should strengthen the training funct ion at KOA and HDOT-A t o ensur e suf fic ient resources are availab le

Existing tr aining at KOA should be augmented with material from the FAA and other sources such as the American Association of Airport Exec ut ives

ARFF per sonnel should be tr ained to conduct inspections of all f ueling oper ations on the air port

HDOT-A should develop and pr ovide a training module in inspection tec hniques

During Jac obs Consultancy rsquos visits to KOA a number of issues were ident if ied that have the pot ential to impact the safety of passengers air por t employ ees or dam age equipment These issues should be reviewed by KOA the Air por t Safety Comm ittee and Saf ety Risk Managem ent as part of the SMS proc ess The SMS Manual w il l descr ibe these pr ocesses These issues wil l also be used for SMS training purposes The issues outlined in Appendix B of t his r epor t ar e as f ollows

Ramp congestion part icularly with increasing t raff ic volumes

Operations at the commuter ter minal

Fueling operations and the lack of fuel st orage capacity and

Very rough terr ain due t o lava fields outs ide of the graded runway safety ar eas

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I INTRODUCTION

Background

In Februar y 2007 the FAA issued Advisory Circular AC 1505200-37 Int roduction to Safety Managem ent Systems (SMS) for Airport Operator s t o introduce the concepts of SMS The F AA has also opened ar ulem aking project to consider f ormal requir ements for SMS at certified airports In support of t his rulemaking effort the FAA has init iat ed a pilot pr ogram to ass ist airpor ts in the developm ent of an SMS specif ic to their sit uation and operat ions and t o shar e their acquired exper ienc e on SMS dev elopm ent and implement ation with other airports and the FAA

The Hawaii Depar tment of Tr ansport ation Air por ts Divis ion (HDOT-A) has dec ided to take a leadership role in the development and im plem entation of SMS at the Kona Internat ional Air port at Keahole (KOA) by part icipating in the FAA pilot program

As part of t he pilot program HDOT-A has r etained the services of Jacobs Consult ancy t o provide consult ing ser vic es to develop a Saf ety Managem ent System (SMS) Program f or KOA

Ob jectives

The specific objectives and deliv erables of t heSMS dev elopment pr oject include

1 AGap Analysis The gap analys is wil l ident ify procedur espolicies doc um entat ionand actions that HDOT-Aand K OA need t o implement as par t of its SMSt hat go beyond the current Par t 139 r equir ements

2 A Draf t Plan A draft of t he com plete SMS Manual and Program Plan

3 The Final Plan The final copy of SMS Manual and Progr am Plan ready f or implement ation by KOA and HDOT-A The FAArsquos requirem ents for the Gap Analysis SMS Manual and Progr am Plan are included in Appendix A

4 Training of KOA and HDOT-A Divis ional employees in SMS

This repor t addresses t he Gap Analys is Phase 2 of t he SMS pr oject wil l develop the SMS for KOA and document it in an SMS Manual and Progr am Plan

The Gap Analys is addr esses what needs to be developed and im plem ented beyond the requirem ents of current Part 139 Our analy sis was not an audit of existing KOA polic ies and procedures as t o their adequacy completeness or c ompliance wit h Par t 139 requirem ents This is t hesubject of detai led F AAc er tification audits which is well beyond t hescopeof this project However based on our review of document ation and discussions wit h KOA and HDOT-A managers we have added in the r eport where appropriate a number of obser vations on ex ist ing practices and policies for considerat ion by HDOT-A Dur ing Jacobs Consult ancyrsquos visits to KOA a number of issues were also identified that have the potential to impact the safet y of passenger s air port em ployees or damage equipm ent These issues should be reviewed by KOA the Airport Safety Committee and Saf ety Risk Managem ent as part of the SMS pr oc ess The SMS Manual wil l describe t hese processes These issues wil l also be used for SMSt raining pur poses The issues are outlined in Appendix B

Methodology Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

1

Jac obs Consultancy pr epared the Gap Analy sis based on

Relevant FAA documentation including

Advisor y Circular AC 150 5200-37 February 2007

TheDraf t Statem ent of Work (SOW) for t heSMS Airport Pilot St udy

Relevant HDOT-A and KOA documentat ion

Selected inter views w it h HDOT-A Div ision manager s and KOAm anagers and supervisors

Guidelines regarding SMS from theInter national Civi l Av iation Organization (ICAO) and

The consult ing team rsquos exper ience wit h t he preparation of SMSf or other air ports

Operations at KOA

Kona Internat ional Airport at Keahole (KOA) is located on the luxurious Kona Gold Coast of West Hawaii KOA is operat ed by the Stat e of Hawaiirsquos Departm ent of Tr ansportation Air ports Div is ion and occupies 4204 acr es of land 9 miles northwest of the central business distr ict of KailuaKona The single story open-air set of terminal st ructur es is locat ed on the eastern edge of the airport and accomm odates domestic overseas inter national inter-island c om muterair t axi and general aviation activities Kona Internationalrsquos daily operations include a wide r ange of air craft such as CRJ-200 B-767 B-737 B-757 B-717 B-777 and B-747 aircraft from m any domest ic and inter national air car riers as well as general aviat ion and US mil itary airc raft In 2006 there were 143411 operations3033000 passengers 23900 tons of cargo and 8512 tons of mail

The Airport has an 11000-f oot r unway and a com plex of f acilities at t he sout hern edge of the airf ield f or air car go and mail air por t suppor t and general aviat ion operations An additional complex of facilit ies used primar ily by rental car agencies f or r eturns gener al maintenance and storage is located along the air port access r oadway midway between the passenger terminals and the main highway General aviation cargo and related fac ilit ies are located to t hesouth of the passenger terminalsand the access roadway

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Stru cture o f the Gap An alysi s

The Gap Analys is is s tructur ed to addr ess the f our element s of an SMS as out lined in the F AArsquos Advisory Circular As well we have added a separate element for Safet y Organization which t he Advisory Circular descr ibed under Safety Policy and Objectives In previous FAA pilot pr oject s that we conducted the FAA SMS Progr am Of ficeagr eed t o t his st ructur e

1 Safet y Polic ies and Objectives

2 Safet y Organization

3 Safet y Risk Managem ent

4 Safet y Assurance

5 Safet y Pr omotion

Under each of these five element s the Gap Analysis addresses t he FAArsquos detailed SMS Program content outlined in the FAA Advisor y Circular AC 1505200-37 and the F AA Draft St atem ent of Wor k (Appendix A)

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stemJT71 5500

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Gap An a Kona Inte rnational Airpo rt at Keahole Safety Management Sy

JT

Mor especif ical ly f or each element the Gap Analysis

1 Summ arizes the F AArsquos SMS guidance doc um entat ion internat ional guidance m ater ial where appropriate and J acobrsquos Consultancy Team rsquos SMS experience

2 Describes what systems policies and practices ex ist at KOA and then

3 Ident if ies procedures policies object ives organizational issues and document ation (ie Gaps) that need to be developed for SMS and how they will be addr essed in t he subsequent tasks to develop the SMS Manualand Saf ety Program Plan

Intent of SMS

The intent of SMS is t o im prove aviation safety The elimination of av iat ion acc idents is a desir able goal However no human activity or human-made syst em can be guar anteed t o be absolutely safe Failur es and err ors will occur in spite of best eff orts to avoid them Alt hough major air disasters are rare events less cat astrophic accident s and a whole rangeof incidents occur more fr equently Ignor ing these underlying saf ety hazar ds could pot entially pave the way for an inc rease in t he number of more serious accidents

The air transportat ion indust ryrsquos future viabilit y may well be pr ed icat ed on its ability to sust ain the publicrsquos perceived safety while traveling The m anagement of safety is therefore a pr erequisite for a sustainable aviation business

The accident rate in t he air transport industry has decreased dram atically between t he early 60rsquos and t hem id 80rsquos from 30 to near 2 per mill ion departures It could be easily argued t hat this rate was achieved f rom continuing efforts by the industry t o m akeair tr avela saf em odeof tr ansport ation But as the following diagram illustr ates bet ween the mid eighties and now we find an 80 incr ease in air tr aff ic and a 73 inc rease in the number of accidents Alt hough the accident rate per mill ion departures rem ains st eady at 2 air tr avel saf ety as perceived by thepublic is l ikely to dec line if traf fic gr owt h and accident rate per million depart ures rem ain the sam e Air t ravel relat ed accidents make instant worldwide news and there will be m ore and more reports even while maintaining a relat ively low accident rat e Safet y m anagement when well in p lace within the industry wil l be a key f actor in f urther reducing the accident r ate and achieving act ual and perceived impr ov ement in aviation s afety

7155 00

4 ly si s stem

Sou rce In tern a l Jacobs Con su ltancy for illu stra tive p u rpose s

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II SAFETY POLICIES AND OBJECTIVES

Key Featu res

The FAASOW f or SMS stat es that Safety Policies and Object ives should include

Written saf ety policy stat ement (s) and a descr iption of how it is communicat ed to airport em ployees and

Ident if icat ion and description of the air port saf ety goals

The FAA Adv isor y Circular under Saf ety Policy indic ates that managem entrsquos c ommitm ent to safety should be formally expr essed in a stat ement of safety policy t hat reflects theairpor trsquossafety philosophy and that iss igned by Top Management

Key attr ibutes of t hepolicy could also include the following

The commitm ent of senior m anagem ent to implem ent SMS

Stat es the air portrsquos intentions management princ iples and comm it ment to continuous improvement to safety at the air port

Is com municated to all employ ees

Is implemented at al l levels of the airport

Confir ms that safet y is every onersquos responsibil ity and

Recognizes that there will alway s be threats to safety and that the air port will provide the highest reasonable standard of safety The Advisory Cir cular refers to a comm it ment to make safet y t he highest priorit y which m ay have adiff erent meaning

The Adv isor y Circular under Safet y Objectives ( Section 222) does not address object ives but deals w it h the organization f or safety The Advisory Circular does r efer to safety perform ance indicat ors and tar gets under Saf ety Assurance ( Section 24)

SMS guidelines inc luding the FAA Advisory Circular g ive very l it tle practical advice on safety goals or objectives The t erms ldquogoalsrdquo and ldquoobjectives rdquo as well as ldquotargets rdquo are frequently used interchangeably The intent in the guidelines nonetheless is to have measurableindicators of safety

Existing Poli cies an d Objectives

HDOT-A has an Em ployee Safet y and Health Pr ogram which is based primarily on the r equir ements of the Hawaii Occupational Safety and Health (HIOSH) standards for the benefit and general welfare of HDOT-A em ployees HDOT-Arsquos occupational saf ety and health st ated policy is t o provide a safe accident-free and healthy wor kenvironm ent for its employees in ar eas such as

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Personal Pr otect ive Equipment (PPE)

Respiratory Pr otection

Hazardous Wast eOperat ions

Noise Exposure

Hazard Communication

Biological Agent s SARSBlood borne Pathogens

Confined Space and

Vio lence in the Wor kplac e

The Employee Health and Safet y Program is not direct ly related to air side aviation safety which is t he intent of SMS

HDOT-A does not currently have a writt en saf ety policy endorsed by Senior Exec ut ive (Top Managem ent) to indicat et heir com mitment t o aviation safet y which is a key element of an SMS

Gaps and Developmen t Required

Safety Policies

Phase 2 of theSMS project wi ll need to develop and docum ent aviation safety policies that should be endorsed by HDOT-A

Note In the developm ent of SMS som e airports have consider ed com bining SMS and employee safety in one document Initial comm ents from HDOT-A managem ent have also suggested that this integrat ion be considered However one docum ent wil l likely not be feasible or pract icable Jacobs Consultancy discussions wit h the FAA have indicated that SMS will event ually be part of the Airport Cer tification Manual (ACM) in the fut ure and that they are not interest ed or concerned with Occupational Saf ety and Health Issues or requirem ents Requirem ents by t he Hawaii Occupational and Health and by the F AA are not the sam e (for exam ple r eporting and risk analyses differ ) Although one safet y docum ent is not pr acticable we do believe that wit hin t he KOA and HDOT-A organiz ation t hose cur rently involved in safety could pot entia lly also be involved in SMS f or example a safet y of fice or off ic er that addresses both SMS and HIOSH requirem ents This organization ar rangem ent will be considered further in t he subsequent Phase 2 of this project to develop the SMS

Safety Objectives

Saf ety objectives are also requir ed to allow for assessm ent of saf ety performance and developments at the airport Safet y objectives should be linked to f actor s such as

Safety hazards identified during inspections eg type and quantity of FOD (Not e the airport rsquos self-inspect ion program captur es this infor mat ion but does not systematically monitor tr ends in this information)

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

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Airs id e safety violations

Aircr aft bird strikes

Incurs ions of vehicles aircraf tor pedest rians on movement ar eas

Ac cidents and incident s on the AOA andor the contr olled m ov ement area involving air carr ier aircraft andor ground v ehicles

Oper able time of lighting systems

Number of airs ide based employees who have received safety and SMSr elat ed t raining

Non-punitivesafet y r eports and

Airport Tower operat ing times

The safety object ives wil l need t o be inc luded in the Airport Dist rict Managerrsquos st atem ent of policy and objectives and then communicated to all of the organization They should be no diff erent f rom other organizationalobjectives in that they should be

Specific and measurable

Achiev able and challenging and

Realized within a specific t im e fram e

Mor especif ic saf ety object ivesapplicable to KOA will be d eveloped during Phase2 of the SMS pilot project

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8

III SAFETY ORGANIZATION

Key Featu res

The FAASOW f or SMS describes the follow ing requirem ent related to t hesafety organizat ion

An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel such as the following

Top Ma na gement

Saf ety Manager

Depart ment HeadsManagers

Established Saf ety Com mittees and Chairpersons

The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety The key feat ures descr ibed in the Advisory Cir cular ar eas follows

SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent) onewith t heaut hority to adequately c ontrolr esources beassigned SMSr esponsibil it ies

Defined saf ety authorities and responsibil ities f or allkey personnel that are assigned to the air port

Ident if icat ion within the system of som eoner esponsible for adm inistr ation of the overall SMS Often that one responsible person wil l be t he Safety Manager This person report s to the highest level of managem ent to assur eappr opriate consider ation of all repor ts r ecomm endations and issues

At m any air por ts oper ationsm ay support the Safety Manager being af ull-time perm anent employ ee and in som ecases having a support st aff

The responsibil ities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within theor ganizat ion

Depending on the s ize and com plex ity of the air por trsquos oper ation it may be useful to establish an Air port Safet y Committee (ASC) The safety committ ee ac ts as asource of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager

The SMS should also address how and to what extent t enants at t he airport such as the air lines fuel ing companies and ground handler s are integr ated into the airport SMS ICAO has m ade very strong ref erence to the inclusion of t enants at an airport ICAOrsquos Safet y Managem ent Manual Doc 9859 A460 Fir st Edition ndash 2006 chapter 18 ndashAER ODROME OPERATIONS statest hat

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Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

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The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

Gap Analy sis 11 KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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1 4

AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

1 6

Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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1 8

IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

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Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

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Appendix C

Inspection Checklists

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Appendix D

Examples of Safety and Security Enforcement Programs

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Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

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Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

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Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

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App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

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Gap AnalysisKona International Airport at Keahole Safety Management System

Table of Cont ents

Section Page

EXECUTIVE SUMMARY i

I IN TRODUCTION 1 Background 1 Objectives 1 Methodology Oper ations at KOA 2 Struct ure of TheGap Analysis 3

II SAFETY P OLICIES AN D OBJECTIVES 6 Key Features 6 Existing Policies And Object ives 6 Gaps and Development Required 7

III SAFETY ORGAN IZATION 9 Key Features 9 Existing Policies Pr actices and Sy stem s 10 Gaps and Development Required 16

IV SAFETY R ISK MAN AGEMENT 19 Key Features 19 Existing Pract icesand Syst ems 19 Gaps and Development Required 19

V SAFETY ASSURANCE 21 Key Features 21 Existing Pract icesAnd Syst ems 22 Gaps and Development Required 24

VI SAFETY PR OMOTION - TRAININ G 25 Key Features 25 Existing Policies Pr actices and Sy stem s 25 Gaps and Development Required 26

VII SAFETY PR OMOTION - COMMUNICATION S 27 Key Features 27 Existing Policies Pr actices and Sy stem s 27 Gaps and Development Required 27

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Dele ted 2

Dele ted 2 0

Dele ted 1 9

Dele ted 2 0

Dele ted 1 9

Dele ted 2 0

Dele ted 1 9

Dele ted 2 0

Dele ted 1 9

Dele ted 2 2

Dele ted 2 1

Dele ted 2 2

Dele ted 2 1

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Dele ted 2 9

Dele ted 2 8

LIST OF APPENDICES

Appendix A Draft St atem ent Of Wor k - FAA SMS Airpor t Pilot Study

Appendix B Saf ety Issues

Appendix C Inspection Checklists

Appendix D Exam ples of Saf ety and Sec ur it y Enforcem ent Programs

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EXECU TIVE SUMMA RY

In Februar y 2007 the FAA issued Advisory Circular AC 1505200-37 Int roduction to Safety Managem ent Systems (SMS) for Airport Operator s to int roduce the concepts of SMS The FAA also init iated a pilot program to assist airports in the development of an SMS specific t o their s it uation and oper ations and to shar e their acquired experience on SMS development and implem entation with other airports and the FAA

The Hawaii Depar tment of Tr ansport ation Air por ts Divis ion (HDOT-A) has dec ided to take a leadership r ole in the development and im plem entation of SMS at the Kona Internat ional Air port at Keahole (KOA) by part icipating in the FAA pilot program

The purpose of this docum ent is t o provide aGap Analysis to ident ify procedur es policies docum entation and act ions that HDOT-A and KOA need to implement as part of its SMS that go beyond the c urrent FARs Part 139 requirem ents The Gap Analysis out lines SMS requirements and com pares them with Part 139 requir ements

As detai led in t his report the gaps between exist ing requir ements and the FAArsquos anticipated SMS r egulat ions and guidance mat erial are as fol lows

Safety Policies and Objectives

Specific aviation saf ety policies and objectives need to be developed for inclusion in the SMS The Gap Analys is outlines key fact ors t hat should be consider ed in Safety Objectives and t hat will be further elabor ated in the SMS Manual

Safety Organization

HDOT-A and KOA do not have an or ganizat ional structur e defined specific ally for addr essing the requirement s of an SMS including the role of top management The Gap Analys is detai ls the pot ential safety or ganization for consideration f or the SMS Manual including the role of the Dist rict Engineer in conducting safety risk management assessments( operational risk assessm ents) for projects

Safety Risk Management

KOA current ly does not have a formal Saf ety Risk Management ( SRM) processf or aviation saf ety The SRM process will be d eveloped and documented during Phase 2

Safety Assurance

Phase 2 will dev elop

o Non-punitive reporting

o System atic reviews and audits

o Safety over sight

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Safety Training and Communication

Gaps include

o SMS training

o Av iat ion safet y pr ograms

Phase 2 will dev elop the SMS based on the gaps identif ied

During the Gap Analysis J acobs Consultancy also made a num ber of observations on existing prac tic es and policies curr ently required under FARs Part 139 Not necessar ily part of an SMS these observations for considerat ion by KOA and HDOT-A are as follows

The HDOT-A should consider making the wearing of safety vests mandatory for all personnel working on the AOA

HDOT-A should consider am ore structured Enfor cement Progr am for specif ied airsid e safety violat ions

HDOT-A should strengthen the training funct ion at KOA and HDOT-A t o ensur e suf fic ient resources are availab le

Existing tr aining at KOA should be augmented with material from the FAA and other sources such as the American Association of Airport Exec ut ives

ARFF per sonnel should be tr ained to conduct inspections of all f ueling oper ations on the air port

HDOT-A should develop and pr ovide a training module in inspection tec hniques

During Jac obs Consultancy rsquos visits to KOA a number of issues were ident if ied that have the pot ential to impact the safety of passengers air por t employ ees or dam age equipment These issues should be reviewed by KOA the Air por t Safety Comm ittee and Saf ety Risk Managem ent as part of the SMS proc ess The SMS Manual w il l descr ibe these pr ocesses These issues wil l also be used for SMS training purposes The issues outlined in Appendix B of t his r epor t ar e as f ollows

Ramp congestion part icularly with increasing t raff ic volumes

Operations at the commuter ter minal

Fueling operations and the lack of fuel st orage capacity and

Very rough terr ain due t o lava fields outs ide of the graded runway safety ar eas

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ii

I INTRODUCTION

Background

In Februar y 2007 the FAA issued Advisory Circular AC 1505200-37 Int roduction to Safety Managem ent Systems (SMS) for Airport Operator s t o introduce the concepts of SMS The F AA has also opened ar ulem aking project to consider f ormal requir ements for SMS at certified airports In support of t his rulemaking effort the FAA has init iat ed a pilot pr ogram to ass ist airpor ts in the developm ent of an SMS specif ic to their sit uation and operat ions and t o shar e their acquired exper ienc e on SMS dev elopm ent and implement ation with other airports and the FAA

The Hawaii Depar tment of Tr ansport ation Air por ts Divis ion (HDOT-A) has dec ided to take a leadership role in the development and im plem entation of SMS at the Kona Internat ional Air port at Keahole (KOA) by part icipating in the FAA pilot program

As part of t he pilot program HDOT-A has r etained the services of Jacobs Consult ancy t o provide consult ing ser vic es to develop a Saf ety Managem ent System (SMS) Program f or KOA

Ob jectives

The specific objectives and deliv erables of t heSMS dev elopment pr oject include

1 AGap Analysis The gap analys is wil l ident ify procedur espolicies doc um entat ionand actions that HDOT-Aand K OA need t o implement as par t of its SMSt hat go beyond the current Par t 139 r equir ements

2 A Draf t Plan A draft of t he com plete SMS Manual and Program Plan

3 The Final Plan The final copy of SMS Manual and Progr am Plan ready f or implement ation by KOA and HDOT-A The FAArsquos requirem ents for the Gap Analysis SMS Manual and Progr am Plan are included in Appendix A

4 Training of KOA and HDOT-A Divis ional employees in SMS

This repor t addresses t he Gap Analys is Phase 2 of t he SMS pr oject wil l develop the SMS for KOA and document it in an SMS Manual and Progr am Plan

The Gap Analys is addr esses what needs to be developed and im plem ented beyond the requirem ents of current Part 139 Our analy sis was not an audit of existing KOA polic ies and procedures as t o their adequacy completeness or c ompliance wit h Par t 139 requirem ents This is t hesubject of detai led F AAc er tification audits which is well beyond t hescopeof this project However based on our review of document ation and discussions wit h KOA and HDOT-A managers we have added in the r eport where appropriate a number of obser vations on ex ist ing practices and policies for considerat ion by HDOT-A Dur ing Jacobs Consult ancyrsquos visits to KOA a number of issues were also identified that have the potential to impact the safet y of passenger s air port em ployees or damage equipm ent These issues should be reviewed by KOA the Airport Safety Committee and Saf ety Risk Managem ent as part of the SMS pr oc ess The SMS Manual wil l describe t hese processes These issues wil l also be used for SMSt raining pur poses The issues are outlined in Appendix B

Methodology Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

1

Jac obs Consultancy pr epared the Gap Analy sis based on

Relevant FAA documentation including

Advisor y Circular AC 150 5200-37 February 2007

TheDraf t Statem ent of Work (SOW) for t heSMS Airport Pilot St udy

Relevant HDOT-A and KOA documentat ion

Selected inter views w it h HDOT-A Div ision manager s and KOAm anagers and supervisors

Guidelines regarding SMS from theInter national Civi l Av iation Organization (ICAO) and

The consult ing team rsquos exper ience wit h t he preparation of SMSf or other air ports

Operations at KOA

Kona Internat ional Airport at Keahole (KOA) is located on the luxurious Kona Gold Coast of West Hawaii KOA is operat ed by the Stat e of Hawaiirsquos Departm ent of Tr ansportation Air ports Div is ion and occupies 4204 acr es of land 9 miles northwest of the central business distr ict of KailuaKona The single story open-air set of terminal st ructur es is locat ed on the eastern edge of the airport and accomm odates domestic overseas inter national inter-island c om muterair t axi and general aviation activities Kona Internationalrsquos daily operations include a wide r ange of air craft such as CRJ-200 B-767 B-737 B-757 B-717 B-777 and B-747 aircraft from m any domest ic and inter national air car riers as well as general aviat ion and US mil itary airc raft In 2006 there were 143411 operations3033000 passengers 23900 tons of cargo and 8512 tons of mail

The Airport has an 11000-f oot r unway and a com plex of f acilities at t he sout hern edge of the airf ield f or air car go and mail air por t suppor t and general aviat ion operations An additional complex of facilit ies used primar ily by rental car agencies f or r eturns gener al maintenance and storage is located along the air port access r oadway midway between the passenger terminals and the main highway General aviation cargo and related fac ilit ies are located to t hesouth of the passenger terminalsand the access roadway

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2

Stru cture o f the Gap An alysi s

The Gap Analys is is s tructur ed to addr ess the f our element s of an SMS as out lined in the F AArsquos Advisory Circular As well we have added a separate element for Safet y Organization which t he Advisory Circular descr ibed under Safety Policy and Objectives In previous FAA pilot pr oject s that we conducted the FAA SMS Progr am Of ficeagr eed t o t his st ructur e

1 Safet y Polic ies and Objectives

2 Safet y Organization

3 Safet y Risk Managem ent

4 Safet y Assurance

5 Safet y Pr omotion

Under each of these five element s the Gap Analysis addresses t he FAArsquos detailed SMS Program content outlined in the FAA Advisor y Circular AC 1505200-37 and the F AA Draft St atem ent of Wor k (Appendix A)

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3

Gap An a Kona Inte rnational Airpo rt at Keahole Safety Management Sy

JT

Mor especif ical ly f or each element the Gap Analysis

1 Summ arizes the F AArsquos SMS guidance doc um entat ion internat ional guidance m ater ial where appropriate and J acobrsquos Consultancy Team rsquos SMS experience

2 Describes what systems policies and practices ex ist at KOA and then

3 Ident if ies procedures policies object ives organizational issues and document ation (ie Gaps) that need to be developed for SMS and how they will be addr essed in t he subsequent tasks to develop the SMS Manualand Saf ety Program Plan

Intent of SMS

The intent of SMS is t o im prove aviation safety The elimination of av iat ion acc idents is a desir able goal However no human activity or human-made syst em can be guar anteed t o be absolutely safe Failur es and err ors will occur in spite of best eff orts to avoid them Alt hough major air disasters are rare events less cat astrophic accident s and a whole rangeof incidents occur more fr equently Ignor ing these underlying saf ety hazar ds could pot entially pave the way for an inc rease in t he number of more serious accidents

The air transportat ion indust ryrsquos future viabilit y may well be pr ed icat ed on its ability to sust ain the publicrsquos perceived safety while traveling The m anagement of safety is therefore a pr erequisite for a sustainable aviation business

The accident rate in t he air transport industry has decreased dram atically between t he early 60rsquos and t hem id 80rsquos from 30 to near 2 per mill ion departures It could be easily argued t hat this rate was achieved f rom continuing efforts by the industry t o m akeair tr avela saf em odeof tr ansport ation But as the following diagram illustr ates bet ween the mid eighties and now we find an 80 incr ease in air tr aff ic and a 73 inc rease in the number of accidents Alt hough the accident rate per mill ion departures rem ains st eady at 2 air tr avel saf ety as perceived by thepublic is l ikely to dec line if traf fic gr owt h and accident rate per million depart ures rem ain the sam e Air t ravel relat ed accidents make instant worldwide news and there will be m ore and more reports even while maintaining a relat ively low accident rat e Safet y m anagement when well in p lace within the industry wil l be a key f actor in f urther reducing the accident r ate and achieving act ual and perceived impr ov ement in aviation s afety

7155 00

4 ly si s stem

Sou rce In tern a l Jacobs Con su ltancy for illu stra tive p u rpose s

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5

II SAFETY POLICIES AND OBJECTIVES

Key Featu res

The FAASOW f or SMS stat es that Safety Policies and Object ives should include

Written saf ety policy stat ement (s) and a descr iption of how it is communicat ed to airport em ployees and

Ident if icat ion and description of the air port saf ety goals

The FAA Adv isor y Circular under Saf ety Policy indic ates that managem entrsquos c ommitm ent to safety should be formally expr essed in a stat ement of safety policy t hat reflects theairpor trsquossafety philosophy and that iss igned by Top Management

Key attr ibutes of t hepolicy could also include the following

The commitm ent of senior m anagem ent to implem ent SMS

Stat es the air portrsquos intentions management princ iples and comm it ment to continuous improvement to safety at the air port

Is com municated to all employ ees

Is implemented at al l levels of the airport

Confir ms that safet y is every onersquos responsibil ity and

Recognizes that there will alway s be threats to safety and that the air port will provide the highest reasonable standard of safety The Advisory Cir cular refers to a comm it ment to make safet y t he highest priorit y which m ay have adiff erent meaning

The Adv isor y Circular under Safet y Objectives ( Section 222) does not address object ives but deals w it h the organization f or safety The Advisory Circular does r efer to safety perform ance indicat ors and tar gets under Saf ety Assurance ( Section 24)

SMS guidelines inc luding the FAA Advisory Circular g ive very l it tle practical advice on safety goals or objectives The t erms ldquogoalsrdquo and ldquoobjectives rdquo as well as ldquotargets rdquo are frequently used interchangeably The intent in the guidelines nonetheless is to have measurableindicators of safety

Existing Poli cies an d Objectives

HDOT-A has an Em ployee Safet y and Health Pr ogram which is based primarily on the r equir ements of the Hawaii Occupational Safety and Health (HIOSH) standards for the benefit and general welfare of HDOT-A em ployees HDOT-Arsquos occupational saf ety and health st ated policy is t o provide a safe accident-free and healthy wor kenvironm ent for its employees in ar eas such as

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Personal Pr otect ive Equipment (PPE)

Respiratory Pr otection

Hazardous Wast eOperat ions

Noise Exposure

Hazard Communication

Biological Agent s SARSBlood borne Pathogens

Confined Space and

Vio lence in the Wor kplac e

The Employee Health and Safet y Program is not direct ly related to air side aviation safety which is t he intent of SMS

HDOT-A does not currently have a writt en saf ety policy endorsed by Senior Exec ut ive (Top Managem ent) to indicat et heir com mitment t o aviation safet y which is a key element of an SMS

Gaps and Developmen t Required

Safety Policies

Phase 2 of theSMS project wi ll need to develop and docum ent aviation safety policies that should be endorsed by HDOT-A

Note In the developm ent of SMS som e airports have consider ed com bining SMS and employee safety in one document Initial comm ents from HDOT-A managem ent have also suggested that this integrat ion be considered However one docum ent wil l likely not be feasible or pract icable Jacobs Consultancy discussions wit h the FAA have indicated that SMS will event ually be part of the Airport Cer tification Manual (ACM) in the fut ure and that they are not interest ed or concerned with Occupational Saf ety and Health Issues or requirem ents Requirem ents by t he Hawaii Occupational and Health and by the F AA are not the sam e (for exam ple r eporting and risk analyses differ ) Although one safet y docum ent is not pr acticable we do believe that wit hin t he KOA and HDOT-A organiz ation t hose cur rently involved in safety could pot entia lly also be involved in SMS f or example a safet y of fice or off ic er that addresses both SMS and HIOSH requirem ents This organization ar rangem ent will be considered further in t he subsequent Phase 2 of this project to develop the SMS

Safety Objectives

Saf ety objectives are also requir ed to allow for assessm ent of saf ety performance and developments at the airport Safet y objectives should be linked to f actor s such as

Safety hazards identified during inspections eg type and quantity of FOD (Not e the airport rsquos self-inspect ion program captur es this infor mat ion but does not systematically monitor tr ends in this information)

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7

Airs id e safety violations

Aircr aft bird strikes

Incurs ions of vehicles aircraf tor pedest rians on movement ar eas

Ac cidents and incident s on the AOA andor the contr olled m ov ement area involving air carr ier aircraft andor ground v ehicles

Oper able time of lighting systems

Number of airs ide based employees who have received safety and SMSr elat ed t raining

Non-punitivesafet y r eports and

Airport Tower operat ing times

The safety object ives wil l need t o be inc luded in the Airport Dist rict Managerrsquos st atem ent of policy and objectives and then communicated to all of the organization They should be no diff erent f rom other organizationalobjectives in that they should be

Specific and measurable

Achiev able and challenging and

Realized within a specific t im e fram e

Mor especif ic saf ety object ivesapplicable to KOA will be d eveloped during Phase2 of the SMS pilot project

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8

III SAFETY ORGANIZATION

Key Featu res

The FAASOW f or SMS describes the follow ing requirem ent related to t hesafety organizat ion

An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel such as the following

Top Ma na gement

Saf ety Manager

Depart ment HeadsManagers

Established Saf ety Com mittees and Chairpersons

The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety The key feat ures descr ibed in the Advisory Cir cular ar eas follows

SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent) onewith t heaut hority to adequately c ontrolr esources beassigned SMSr esponsibil it ies

Defined saf ety authorities and responsibil ities f or allkey personnel that are assigned to the air port

Ident if icat ion within the system of som eoner esponsible for adm inistr ation of the overall SMS Often that one responsible person wil l be t he Safety Manager This person report s to the highest level of managem ent to assur eappr opriate consider ation of all repor ts r ecomm endations and issues

At m any air por ts oper ationsm ay support the Safety Manager being af ull-time perm anent employ ee and in som ecases having a support st aff

The responsibil ities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within theor ganizat ion

Depending on the s ize and com plex ity of the air por trsquos oper ation it may be useful to establish an Air port Safet y Committee (ASC) The safety committ ee ac ts as asource of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager

The SMS should also address how and to what extent t enants at t he airport such as the air lines fuel ing companies and ground handler s are integr ated into the airport SMS ICAO has m ade very strong ref erence to the inclusion of t enants at an airport ICAOrsquos Safet y Managem ent Manual Doc 9859 A460 Fir st Edition ndash 2006 chapter 18 ndashAER ODROME OPERATIONS statest hat

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Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

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The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

Gap Analy sis 11 KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

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Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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JT 7155 00

2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

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LIST OF APPENDICES

Appendix A Draft St atem ent Of Wor k - FAA SMS Airpor t Pilot Study

Appendix B Saf ety Issues

Appendix C Inspection Checklists

Appendix D Exam ples of Saf ety and Sec ur it y Enforcem ent Programs

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EXECU TIVE SUMMA RY

In Februar y 2007 the FAA issued Advisory Circular AC 1505200-37 Int roduction to Safety Managem ent Systems (SMS) for Airport Operator s to int roduce the concepts of SMS The FAA also init iated a pilot program to assist airports in the development of an SMS specific t o their s it uation and oper ations and to shar e their acquired experience on SMS development and implem entation with other airports and the FAA

The Hawaii Depar tment of Tr ansport ation Air por ts Divis ion (HDOT-A) has dec ided to take a leadership r ole in the development and im plem entation of SMS at the Kona Internat ional Air port at Keahole (KOA) by part icipating in the FAA pilot program

The purpose of this docum ent is t o provide aGap Analysis to ident ify procedur es policies docum entation and act ions that HDOT-A and KOA need to implement as part of its SMS that go beyond the c urrent FARs Part 139 requirem ents The Gap Analysis out lines SMS requirements and com pares them with Part 139 requir ements

As detai led in t his report the gaps between exist ing requir ements and the FAArsquos anticipated SMS r egulat ions and guidance mat erial are as fol lows

Safety Policies and Objectives

Specific aviation saf ety policies and objectives need to be developed for inclusion in the SMS The Gap Analys is outlines key fact ors t hat should be consider ed in Safety Objectives and t hat will be further elabor ated in the SMS Manual

Safety Organization

HDOT-A and KOA do not have an or ganizat ional structur e defined specific ally for addr essing the requirement s of an SMS including the role of top management The Gap Analys is detai ls the pot ential safety or ganization for consideration f or the SMS Manual including the role of the Dist rict Engineer in conducting safety risk management assessments( operational risk assessm ents) for projects

Safety Risk Management

KOA current ly does not have a formal Saf ety Risk Management ( SRM) processf or aviation saf ety The SRM process will be d eveloped and documented during Phase 2

Safety Assurance

Phase 2 will dev elop

o Non-punitive reporting

o System atic reviews and audits

o Safety over sight

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i

Safety Training and Communication

Gaps include

o SMS training

o Av iat ion safet y pr ograms

Phase 2 will dev elop the SMS based on the gaps identif ied

During the Gap Analysis J acobs Consultancy also made a num ber of observations on existing prac tic es and policies curr ently required under FARs Part 139 Not necessar ily part of an SMS these observations for considerat ion by KOA and HDOT-A are as follows

The HDOT-A should consider making the wearing of safety vests mandatory for all personnel working on the AOA

HDOT-A should consider am ore structured Enfor cement Progr am for specif ied airsid e safety violat ions

HDOT-A should strengthen the training funct ion at KOA and HDOT-A t o ensur e suf fic ient resources are availab le

Existing tr aining at KOA should be augmented with material from the FAA and other sources such as the American Association of Airport Exec ut ives

ARFF per sonnel should be tr ained to conduct inspections of all f ueling oper ations on the air port

HDOT-A should develop and pr ovide a training module in inspection tec hniques

During Jac obs Consultancy rsquos visits to KOA a number of issues were ident if ied that have the pot ential to impact the safety of passengers air por t employ ees or dam age equipment These issues should be reviewed by KOA the Air por t Safety Comm ittee and Saf ety Risk Managem ent as part of the SMS proc ess The SMS Manual w il l descr ibe these pr ocesses These issues wil l also be used for SMS training purposes The issues outlined in Appendix B of t his r epor t ar e as f ollows

Ramp congestion part icularly with increasing t raff ic volumes

Operations at the commuter ter minal

Fueling operations and the lack of fuel st orage capacity and

Very rough terr ain due t o lava fields outs ide of the graded runway safety ar eas

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ii

I INTRODUCTION

Background

In Februar y 2007 the FAA issued Advisory Circular AC 1505200-37 Int roduction to Safety Managem ent Systems (SMS) for Airport Operator s t o introduce the concepts of SMS The F AA has also opened ar ulem aking project to consider f ormal requir ements for SMS at certified airports In support of t his rulemaking effort the FAA has init iat ed a pilot pr ogram to ass ist airpor ts in the developm ent of an SMS specif ic to their sit uation and operat ions and t o shar e their acquired exper ienc e on SMS dev elopm ent and implement ation with other airports and the FAA

The Hawaii Depar tment of Tr ansport ation Air por ts Divis ion (HDOT-A) has dec ided to take a leadership role in the development and im plem entation of SMS at the Kona Internat ional Air port at Keahole (KOA) by part icipating in the FAA pilot program

As part of t he pilot program HDOT-A has r etained the services of Jacobs Consult ancy t o provide consult ing ser vic es to develop a Saf ety Managem ent System (SMS) Program f or KOA

Ob jectives

The specific objectives and deliv erables of t heSMS dev elopment pr oject include

1 AGap Analysis The gap analys is wil l ident ify procedur espolicies doc um entat ionand actions that HDOT-Aand K OA need t o implement as par t of its SMSt hat go beyond the current Par t 139 r equir ements

2 A Draf t Plan A draft of t he com plete SMS Manual and Program Plan

3 The Final Plan The final copy of SMS Manual and Progr am Plan ready f or implement ation by KOA and HDOT-A The FAArsquos requirem ents for the Gap Analysis SMS Manual and Progr am Plan are included in Appendix A

4 Training of KOA and HDOT-A Divis ional employees in SMS

This repor t addresses t he Gap Analys is Phase 2 of t he SMS pr oject wil l develop the SMS for KOA and document it in an SMS Manual and Progr am Plan

The Gap Analys is addr esses what needs to be developed and im plem ented beyond the requirem ents of current Part 139 Our analy sis was not an audit of existing KOA polic ies and procedures as t o their adequacy completeness or c ompliance wit h Par t 139 requirem ents This is t hesubject of detai led F AAc er tification audits which is well beyond t hescopeof this project However based on our review of document ation and discussions wit h KOA and HDOT-A managers we have added in the r eport where appropriate a number of obser vations on ex ist ing practices and policies for considerat ion by HDOT-A Dur ing Jacobs Consult ancyrsquos visits to KOA a number of issues were also identified that have the potential to impact the safet y of passenger s air port em ployees or damage equipm ent These issues should be reviewed by KOA the Airport Safety Committee and Saf ety Risk Managem ent as part of the SMS pr oc ess The SMS Manual wil l describe t hese processes These issues wil l also be used for SMSt raining pur poses The issues are outlined in Appendix B

Methodology Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

1

Jac obs Consultancy pr epared the Gap Analy sis based on

Relevant FAA documentation including

Advisor y Circular AC 150 5200-37 February 2007

TheDraf t Statem ent of Work (SOW) for t heSMS Airport Pilot St udy

Relevant HDOT-A and KOA documentat ion

Selected inter views w it h HDOT-A Div ision manager s and KOAm anagers and supervisors

Guidelines regarding SMS from theInter national Civi l Av iation Organization (ICAO) and

The consult ing team rsquos exper ience wit h t he preparation of SMSf or other air ports

Operations at KOA

Kona Internat ional Airport at Keahole (KOA) is located on the luxurious Kona Gold Coast of West Hawaii KOA is operat ed by the Stat e of Hawaiirsquos Departm ent of Tr ansportation Air ports Div is ion and occupies 4204 acr es of land 9 miles northwest of the central business distr ict of KailuaKona The single story open-air set of terminal st ructur es is locat ed on the eastern edge of the airport and accomm odates domestic overseas inter national inter-island c om muterair t axi and general aviation activities Kona Internationalrsquos daily operations include a wide r ange of air craft such as CRJ-200 B-767 B-737 B-757 B-717 B-777 and B-747 aircraft from m any domest ic and inter national air car riers as well as general aviat ion and US mil itary airc raft In 2006 there were 143411 operations3033000 passengers 23900 tons of cargo and 8512 tons of mail

The Airport has an 11000-f oot r unway and a com plex of f acilities at t he sout hern edge of the airf ield f or air car go and mail air por t suppor t and general aviat ion operations An additional complex of facilit ies used primar ily by rental car agencies f or r eturns gener al maintenance and storage is located along the air port access r oadway midway between the passenger terminals and the main highway General aviation cargo and related fac ilit ies are located to t hesouth of the passenger terminalsand the access roadway

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2

Stru cture o f the Gap An alysi s

The Gap Analys is is s tructur ed to addr ess the f our element s of an SMS as out lined in the F AArsquos Advisory Circular As well we have added a separate element for Safet y Organization which t he Advisory Circular descr ibed under Safety Policy and Objectives In previous FAA pilot pr oject s that we conducted the FAA SMS Progr am Of ficeagr eed t o t his st ructur e

1 Safet y Polic ies and Objectives

2 Safet y Organization

3 Safet y Risk Managem ent

4 Safet y Assurance

5 Safet y Pr omotion

Under each of these five element s the Gap Analysis addresses t he FAArsquos detailed SMS Program content outlined in the FAA Advisor y Circular AC 1505200-37 and the F AA Draft St atem ent of Wor k (Appendix A)

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3

Gap An a Kona Inte rnational Airpo rt at Keahole Safety Management Sy

JT

Mor especif ical ly f or each element the Gap Analysis

1 Summ arizes the F AArsquos SMS guidance doc um entat ion internat ional guidance m ater ial where appropriate and J acobrsquos Consultancy Team rsquos SMS experience

2 Describes what systems policies and practices ex ist at KOA and then

3 Ident if ies procedures policies object ives organizational issues and document ation (ie Gaps) that need to be developed for SMS and how they will be addr essed in t he subsequent tasks to develop the SMS Manualand Saf ety Program Plan

Intent of SMS

The intent of SMS is t o im prove aviation safety The elimination of av iat ion acc idents is a desir able goal However no human activity or human-made syst em can be guar anteed t o be absolutely safe Failur es and err ors will occur in spite of best eff orts to avoid them Alt hough major air disasters are rare events less cat astrophic accident s and a whole rangeof incidents occur more fr equently Ignor ing these underlying saf ety hazar ds could pot entially pave the way for an inc rease in t he number of more serious accidents

The air transportat ion indust ryrsquos future viabilit y may well be pr ed icat ed on its ability to sust ain the publicrsquos perceived safety while traveling The m anagement of safety is therefore a pr erequisite for a sustainable aviation business

The accident rate in t he air transport industry has decreased dram atically between t he early 60rsquos and t hem id 80rsquos from 30 to near 2 per mill ion departures It could be easily argued t hat this rate was achieved f rom continuing efforts by the industry t o m akeair tr avela saf em odeof tr ansport ation But as the following diagram illustr ates bet ween the mid eighties and now we find an 80 incr ease in air tr aff ic and a 73 inc rease in the number of accidents Alt hough the accident rate per mill ion departures rem ains st eady at 2 air tr avel saf ety as perceived by thepublic is l ikely to dec line if traf fic gr owt h and accident rate per million depart ures rem ain the sam e Air t ravel relat ed accidents make instant worldwide news and there will be m ore and more reports even while maintaining a relat ively low accident rat e Safet y m anagement when well in p lace within the industry wil l be a key f actor in f urther reducing the accident r ate and achieving act ual and perceived impr ov ement in aviation s afety

7155 00

4 ly si s stem

Sou rce In tern a l Jacobs Con su ltancy for illu stra tive p u rpose s

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5

II SAFETY POLICIES AND OBJECTIVES

Key Featu res

The FAASOW f or SMS stat es that Safety Policies and Object ives should include

Written saf ety policy stat ement (s) and a descr iption of how it is communicat ed to airport em ployees and

Ident if icat ion and description of the air port saf ety goals

The FAA Adv isor y Circular under Saf ety Policy indic ates that managem entrsquos c ommitm ent to safety should be formally expr essed in a stat ement of safety policy t hat reflects theairpor trsquossafety philosophy and that iss igned by Top Management

Key attr ibutes of t hepolicy could also include the following

The commitm ent of senior m anagem ent to implem ent SMS

Stat es the air portrsquos intentions management princ iples and comm it ment to continuous improvement to safety at the air port

Is com municated to all employ ees

Is implemented at al l levels of the airport

Confir ms that safet y is every onersquos responsibil ity and

Recognizes that there will alway s be threats to safety and that the air port will provide the highest reasonable standard of safety The Advisory Cir cular refers to a comm it ment to make safet y t he highest priorit y which m ay have adiff erent meaning

The Adv isor y Circular under Safet y Objectives ( Section 222) does not address object ives but deals w it h the organization f or safety The Advisory Circular does r efer to safety perform ance indicat ors and tar gets under Saf ety Assurance ( Section 24)

SMS guidelines inc luding the FAA Advisory Circular g ive very l it tle practical advice on safety goals or objectives The t erms ldquogoalsrdquo and ldquoobjectives rdquo as well as ldquotargets rdquo are frequently used interchangeably The intent in the guidelines nonetheless is to have measurableindicators of safety

Existing Poli cies an d Objectives

HDOT-A has an Em ployee Safet y and Health Pr ogram which is based primarily on the r equir ements of the Hawaii Occupational Safety and Health (HIOSH) standards for the benefit and general welfare of HDOT-A em ployees HDOT-Arsquos occupational saf ety and health st ated policy is t o provide a safe accident-free and healthy wor kenvironm ent for its employees in ar eas such as

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Personal Pr otect ive Equipment (PPE)

Respiratory Pr otection

Hazardous Wast eOperat ions

Noise Exposure

Hazard Communication

Biological Agent s SARSBlood borne Pathogens

Confined Space and

Vio lence in the Wor kplac e

The Employee Health and Safet y Program is not direct ly related to air side aviation safety which is t he intent of SMS

HDOT-A does not currently have a writt en saf ety policy endorsed by Senior Exec ut ive (Top Managem ent) to indicat et heir com mitment t o aviation safet y which is a key element of an SMS

Gaps and Developmen t Required

Safety Policies

Phase 2 of theSMS project wi ll need to develop and docum ent aviation safety policies that should be endorsed by HDOT-A

Note In the developm ent of SMS som e airports have consider ed com bining SMS and employee safety in one document Initial comm ents from HDOT-A managem ent have also suggested that this integrat ion be considered However one docum ent wil l likely not be feasible or pract icable Jacobs Consultancy discussions wit h the FAA have indicated that SMS will event ually be part of the Airport Cer tification Manual (ACM) in the fut ure and that they are not interest ed or concerned with Occupational Saf ety and Health Issues or requirem ents Requirem ents by t he Hawaii Occupational and Health and by the F AA are not the sam e (for exam ple r eporting and risk analyses differ ) Although one safet y docum ent is not pr acticable we do believe that wit hin t he KOA and HDOT-A organiz ation t hose cur rently involved in safety could pot entia lly also be involved in SMS f or example a safet y of fice or off ic er that addresses both SMS and HIOSH requirem ents This organization ar rangem ent will be considered further in t he subsequent Phase 2 of this project to develop the SMS

Safety Objectives

Saf ety objectives are also requir ed to allow for assessm ent of saf ety performance and developments at the airport Safet y objectives should be linked to f actor s such as

Safety hazards identified during inspections eg type and quantity of FOD (Not e the airport rsquos self-inspect ion program captur es this infor mat ion but does not systematically monitor tr ends in this information)

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

7

Airs id e safety violations

Aircr aft bird strikes

Incurs ions of vehicles aircraf tor pedest rians on movement ar eas

Ac cidents and incident s on the AOA andor the contr olled m ov ement area involving air carr ier aircraft andor ground v ehicles

Oper able time of lighting systems

Number of airs ide based employees who have received safety and SMSr elat ed t raining

Non-punitivesafet y r eports and

Airport Tower operat ing times

The safety object ives wil l need t o be inc luded in the Airport Dist rict Managerrsquos st atem ent of policy and objectives and then communicated to all of the organization They should be no diff erent f rom other organizationalobjectives in that they should be

Specific and measurable

Achiev able and challenging and

Realized within a specific t im e fram e

Mor especif ic saf ety object ivesapplicable to KOA will be d eveloped during Phase2 of the SMS pilot project

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8

III SAFETY ORGANIZATION

Key Featu res

The FAASOW f or SMS describes the follow ing requirem ent related to t hesafety organizat ion

An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel such as the following

Top Ma na gement

Saf ety Manager

Depart ment HeadsManagers

Established Saf ety Com mittees and Chairpersons

The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety The key feat ures descr ibed in the Advisory Cir cular ar eas follows

SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent) onewith t heaut hority to adequately c ontrolr esources beassigned SMSr esponsibil it ies

Defined saf ety authorities and responsibil ities f or allkey personnel that are assigned to the air port

Ident if icat ion within the system of som eoner esponsible for adm inistr ation of the overall SMS Often that one responsible person wil l be t he Safety Manager This person report s to the highest level of managem ent to assur eappr opriate consider ation of all repor ts r ecomm endations and issues

At m any air por ts oper ationsm ay support the Safety Manager being af ull-time perm anent employ ee and in som ecases having a support st aff

The responsibil ities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within theor ganizat ion

Depending on the s ize and com plex ity of the air por trsquos oper ation it may be useful to establish an Air port Safet y Committee (ASC) The safety committ ee ac ts as asource of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager

The SMS should also address how and to what extent t enants at t he airport such as the air lines fuel ing companies and ground handler s are integr ated into the airport SMS ICAO has m ade very strong ref erence to the inclusion of t enants at an airport ICAOrsquos Safet y Managem ent Manual Doc 9859 A460 Fir st Edition ndash 2006 chapter 18 ndashAER ODROME OPERATIONS statest hat

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Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

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The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

Gap Analy sis 11 KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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JT 7155 00

1 4

AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

1 6

Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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1 8

IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

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Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

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Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

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Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

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Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

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Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

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Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

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Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

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EXECU TIVE SUMMA RY

In Februar y 2007 the FAA issued Advisory Circular AC 1505200-37 Int roduction to Safety Managem ent Systems (SMS) for Airport Operator s to int roduce the concepts of SMS The FAA also init iated a pilot program to assist airports in the development of an SMS specific t o their s it uation and oper ations and to shar e their acquired experience on SMS development and implem entation with other airports and the FAA

The Hawaii Depar tment of Tr ansport ation Air por ts Divis ion (HDOT-A) has dec ided to take a leadership r ole in the development and im plem entation of SMS at the Kona Internat ional Air port at Keahole (KOA) by part icipating in the FAA pilot program

The purpose of this docum ent is t o provide aGap Analysis to ident ify procedur es policies docum entation and act ions that HDOT-A and KOA need to implement as part of its SMS that go beyond the c urrent FARs Part 139 requirem ents The Gap Analysis out lines SMS requirements and com pares them with Part 139 requir ements

As detai led in t his report the gaps between exist ing requir ements and the FAArsquos anticipated SMS r egulat ions and guidance mat erial are as fol lows

Safety Policies and Objectives

Specific aviation saf ety policies and objectives need to be developed for inclusion in the SMS The Gap Analys is outlines key fact ors t hat should be consider ed in Safety Objectives and t hat will be further elabor ated in the SMS Manual

Safety Organization

HDOT-A and KOA do not have an or ganizat ional structur e defined specific ally for addr essing the requirement s of an SMS including the role of top management The Gap Analys is detai ls the pot ential safety or ganization for consideration f or the SMS Manual including the role of the Dist rict Engineer in conducting safety risk management assessments( operational risk assessm ents) for projects

Safety Risk Management

KOA current ly does not have a formal Saf ety Risk Management ( SRM) processf or aviation saf ety The SRM process will be d eveloped and documented during Phase 2

Safety Assurance

Phase 2 will dev elop

o Non-punitive reporting

o System atic reviews and audits

o Safety over sight

Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

i

Safety Training and Communication

Gaps include

o SMS training

o Av iat ion safet y pr ograms

Phase 2 will dev elop the SMS based on the gaps identif ied

During the Gap Analysis J acobs Consultancy also made a num ber of observations on existing prac tic es and policies curr ently required under FARs Part 139 Not necessar ily part of an SMS these observations for considerat ion by KOA and HDOT-A are as follows

The HDOT-A should consider making the wearing of safety vests mandatory for all personnel working on the AOA

HDOT-A should consider am ore structured Enfor cement Progr am for specif ied airsid e safety violat ions

HDOT-A should strengthen the training funct ion at KOA and HDOT-A t o ensur e suf fic ient resources are availab le

Existing tr aining at KOA should be augmented with material from the FAA and other sources such as the American Association of Airport Exec ut ives

ARFF per sonnel should be tr ained to conduct inspections of all f ueling oper ations on the air port

HDOT-A should develop and pr ovide a training module in inspection tec hniques

During Jac obs Consultancy rsquos visits to KOA a number of issues were ident if ied that have the pot ential to impact the safety of passengers air por t employ ees or dam age equipment These issues should be reviewed by KOA the Air por t Safety Comm ittee and Saf ety Risk Managem ent as part of the SMS proc ess The SMS Manual w il l descr ibe these pr ocesses These issues wil l also be used for SMS training purposes The issues outlined in Appendix B of t his r epor t ar e as f ollows

Ramp congestion part icularly with increasing t raff ic volumes

Operations at the commuter ter minal

Fueling operations and the lack of fuel st orage capacity and

Very rough terr ain due t o lava fields outs ide of the graded runway safety ar eas

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ii

I INTRODUCTION

Background

In Februar y 2007 the FAA issued Advisory Circular AC 1505200-37 Int roduction to Safety Managem ent Systems (SMS) for Airport Operator s t o introduce the concepts of SMS The F AA has also opened ar ulem aking project to consider f ormal requir ements for SMS at certified airports In support of t his rulemaking effort the FAA has init iat ed a pilot pr ogram to ass ist airpor ts in the developm ent of an SMS specif ic to their sit uation and operat ions and t o shar e their acquired exper ienc e on SMS dev elopm ent and implement ation with other airports and the FAA

The Hawaii Depar tment of Tr ansport ation Air por ts Divis ion (HDOT-A) has dec ided to take a leadership role in the development and im plem entation of SMS at the Kona Internat ional Air port at Keahole (KOA) by part icipating in the FAA pilot program

As part of t he pilot program HDOT-A has r etained the services of Jacobs Consult ancy t o provide consult ing ser vic es to develop a Saf ety Managem ent System (SMS) Program f or KOA

Ob jectives

The specific objectives and deliv erables of t heSMS dev elopment pr oject include

1 AGap Analysis The gap analys is wil l ident ify procedur espolicies doc um entat ionand actions that HDOT-Aand K OA need t o implement as par t of its SMSt hat go beyond the current Par t 139 r equir ements

2 A Draf t Plan A draft of t he com plete SMS Manual and Program Plan

3 The Final Plan The final copy of SMS Manual and Progr am Plan ready f or implement ation by KOA and HDOT-A The FAArsquos requirem ents for the Gap Analysis SMS Manual and Progr am Plan are included in Appendix A

4 Training of KOA and HDOT-A Divis ional employees in SMS

This repor t addresses t he Gap Analys is Phase 2 of t he SMS pr oject wil l develop the SMS for KOA and document it in an SMS Manual and Progr am Plan

The Gap Analys is addr esses what needs to be developed and im plem ented beyond the requirem ents of current Part 139 Our analy sis was not an audit of existing KOA polic ies and procedures as t o their adequacy completeness or c ompliance wit h Par t 139 requirem ents This is t hesubject of detai led F AAc er tification audits which is well beyond t hescopeof this project However based on our review of document ation and discussions wit h KOA and HDOT-A managers we have added in the r eport where appropriate a number of obser vations on ex ist ing practices and policies for considerat ion by HDOT-A Dur ing Jacobs Consult ancyrsquos visits to KOA a number of issues were also identified that have the potential to impact the safet y of passenger s air port em ployees or damage equipm ent These issues should be reviewed by KOA the Airport Safety Committee and Saf ety Risk Managem ent as part of the SMS pr oc ess The SMS Manual wil l describe t hese processes These issues wil l also be used for SMSt raining pur poses The issues are outlined in Appendix B

Methodology Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

1

Jac obs Consultancy pr epared the Gap Analy sis based on

Relevant FAA documentation including

Advisor y Circular AC 150 5200-37 February 2007

TheDraf t Statem ent of Work (SOW) for t heSMS Airport Pilot St udy

Relevant HDOT-A and KOA documentat ion

Selected inter views w it h HDOT-A Div ision manager s and KOAm anagers and supervisors

Guidelines regarding SMS from theInter national Civi l Av iation Organization (ICAO) and

The consult ing team rsquos exper ience wit h t he preparation of SMSf or other air ports

Operations at KOA

Kona Internat ional Airport at Keahole (KOA) is located on the luxurious Kona Gold Coast of West Hawaii KOA is operat ed by the Stat e of Hawaiirsquos Departm ent of Tr ansportation Air ports Div is ion and occupies 4204 acr es of land 9 miles northwest of the central business distr ict of KailuaKona The single story open-air set of terminal st ructur es is locat ed on the eastern edge of the airport and accomm odates domestic overseas inter national inter-island c om muterair t axi and general aviation activities Kona Internationalrsquos daily operations include a wide r ange of air craft such as CRJ-200 B-767 B-737 B-757 B-717 B-777 and B-747 aircraft from m any domest ic and inter national air car riers as well as general aviat ion and US mil itary airc raft In 2006 there were 143411 operations3033000 passengers 23900 tons of cargo and 8512 tons of mail

The Airport has an 11000-f oot r unway and a com plex of f acilities at t he sout hern edge of the airf ield f or air car go and mail air por t suppor t and general aviat ion operations An additional complex of facilit ies used primar ily by rental car agencies f or r eturns gener al maintenance and storage is located along the air port access r oadway midway between the passenger terminals and the main highway General aviation cargo and related fac ilit ies are located to t hesouth of the passenger terminalsand the access roadway

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

JT 7155 00

2

Stru cture o f the Gap An alysi s

The Gap Analys is is s tructur ed to addr ess the f our element s of an SMS as out lined in the F AArsquos Advisory Circular As well we have added a separate element for Safet y Organization which t he Advisory Circular descr ibed under Safety Policy and Objectives In previous FAA pilot pr oject s that we conducted the FAA SMS Progr am Of ficeagr eed t o t his st ructur e

1 Safet y Polic ies and Objectives

2 Safet y Organization

3 Safet y Risk Managem ent

4 Safet y Assurance

5 Safet y Pr omotion

Under each of these five element s the Gap Analysis addresses t he FAArsquos detailed SMS Program content outlined in the FAA Advisor y Circular AC 1505200-37 and the F AA Draft St atem ent of Wor k (Appendix A)

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stemJT71 5500

3

Gap An a Kona Inte rnational Airpo rt at Keahole Safety Management Sy

JT

Mor especif ical ly f or each element the Gap Analysis

1 Summ arizes the F AArsquos SMS guidance doc um entat ion internat ional guidance m ater ial where appropriate and J acobrsquos Consultancy Team rsquos SMS experience

2 Describes what systems policies and practices ex ist at KOA and then

3 Ident if ies procedures policies object ives organizational issues and document ation (ie Gaps) that need to be developed for SMS and how they will be addr essed in t he subsequent tasks to develop the SMS Manualand Saf ety Program Plan

Intent of SMS

The intent of SMS is t o im prove aviation safety The elimination of av iat ion acc idents is a desir able goal However no human activity or human-made syst em can be guar anteed t o be absolutely safe Failur es and err ors will occur in spite of best eff orts to avoid them Alt hough major air disasters are rare events less cat astrophic accident s and a whole rangeof incidents occur more fr equently Ignor ing these underlying saf ety hazar ds could pot entially pave the way for an inc rease in t he number of more serious accidents

The air transportat ion indust ryrsquos future viabilit y may well be pr ed icat ed on its ability to sust ain the publicrsquos perceived safety while traveling The m anagement of safety is therefore a pr erequisite for a sustainable aviation business

The accident rate in t he air transport industry has decreased dram atically between t he early 60rsquos and t hem id 80rsquos from 30 to near 2 per mill ion departures It could be easily argued t hat this rate was achieved f rom continuing efforts by the industry t o m akeair tr avela saf em odeof tr ansport ation But as the following diagram illustr ates bet ween the mid eighties and now we find an 80 incr ease in air tr aff ic and a 73 inc rease in the number of accidents Alt hough the accident rate per mill ion departures rem ains st eady at 2 air tr avel saf ety as perceived by thepublic is l ikely to dec line if traf fic gr owt h and accident rate per million depart ures rem ain the sam e Air t ravel relat ed accidents make instant worldwide news and there will be m ore and more reports even while maintaining a relat ively low accident rat e Safet y m anagement when well in p lace within the industry wil l be a key f actor in f urther reducing the accident r ate and achieving act ual and perceived impr ov ement in aviation s afety

7155 00

4 ly si s stem

Sou rce In tern a l Jacobs Con su ltancy for illu stra tive p u rpose s

Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

5

II SAFETY POLICIES AND OBJECTIVES

Key Featu res

The FAASOW f or SMS stat es that Safety Policies and Object ives should include

Written saf ety policy stat ement (s) and a descr iption of how it is communicat ed to airport em ployees and

Ident if icat ion and description of the air port saf ety goals

The FAA Adv isor y Circular under Saf ety Policy indic ates that managem entrsquos c ommitm ent to safety should be formally expr essed in a stat ement of safety policy t hat reflects theairpor trsquossafety philosophy and that iss igned by Top Management

Key attr ibutes of t hepolicy could also include the following

The commitm ent of senior m anagem ent to implem ent SMS

Stat es the air portrsquos intentions management princ iples and comm it ment to continuous improvement to safety at the air port

Is com municated to all employ ees

Is implemented at al l levels of the airport

Confir ms that safet y is every onersquos responsibil ity and

Recognizes that there will alway s be threats to safety and that the air port will provide the highest reasonable standard of safety The Advisory Cir cular refers to a comm it ment to make safet y t he highest priorit y which m ay have adiff erent meaning

The Adv isor y Circular under Safet y Objectives ( Section 222) does not address object ives but deals w it h the organization f or safety The Advisory Circular does r efer to safety perform ance indicat ors and tar gets under Saf ety Assurance ( Section 24)

SMS guidelines inc luding the FAA Advisory Circular g ive very l it tle practical advice on safety goals or objectives The t erms ldquogoalsrdquo and ldquoobjectives rdquo as well as ldquotargets rdquo are frequently used interchangeably The intent in the guidelines nonetheless is to have measurableindicators of safety

Existing Poli cies an d Objectives

HDOT-A has an Em ployee Safet y and Health Pr ogram which is based primarily on the r equir ements of the Hawaii Occupational Safety and Health (HIOSH) standards for the benefit and general welfare of HDOT-A em ployees HDOT-Arsquos occupational saf ety and health st ated policy is t o provide a safe accident-free and healthy wor kenvironm ent for its employees in ar eas such as

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Personal Pr otect ive Equipment (PPE)

Respiratory Pr otection

Hazardous Wast eOperat ions

Noise Exposure

Hazard Communication

Biological Agent s SARSBlood borne Pathogens

Confined Space and

Vio lence in the Wor kplac e

The Employee Health and Safet y Program is not direct ly related to air side aviation safety which is t he intent of SMS

HDOT-A does not currently have a writt en saf ety policy endorsed by Senior Exec ut ive (Top Managem ent) to indicat et heir com mitment t o aviation safet y which is a key element of an SMS

Gaps and Developmen t Required

Safety Policies

Phase 2 of theSMS project wi ll need to develop and docum ent aviation safety policies that should be endorsed by HDOT-A

Note In the developm ent of SMS som e airports have consider ed com bining SMS and employee safety in one document Initial comm ents from HDOT-A managem ent have also suggested that this integrat ion be considered However one docum ent wil l likely not be feasible or pract icable Jacobs Consultancy discussions wit h the FAA have indicated that SMS will event ually be part of the Airport Cer tification Manual (ACM) in the fut ure and that they are not interest ed or concerned with Occupational Saf ety and Health Issues or requirem ents Requirem ents by t he Hawaii Occupational and Health and by the F AA are not the sam e (for exam ple r eporting and risk analyses differ ) Although one safet y docum ent is not pr acticable we do believe that wit hin t he KOA and HDOT-A organiz ation t hose cur rently involved in safety could pot entia lly also be involved in SMS f or example a safet y of fice or off ic er that addresses both SMS and HIOSH requirem ents This organization ar rangem ent will be considered further in t he subsequent Phase 2 of this project to develop the SMS

Safety Objectives

Saf ety objectives are also requir ed to allow for assessm ent of saf ety performance and developments at the airport Safet y objectives should be linked to f actor s such as

Safety hazards identified during inspections eg type and quantity of FOD (Not e the airport rsquos self-inspect ion program captur es this infor mat ion but does not systematically monitor tr ends in this information)

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7

Airs id e safety violations

Aircr aft bird strikes

Incurs ions of vehicles aircraf tor pedest rians on movement ar eas

Ac cidents and incident s on the AOA andor the contr olled m ov ement area involving air carr ier aircraft andor ground v ehicles

Oper able time of lighting systems

Number of airs ide based employees who have received safety and SMSr elat ed t raining

Non-punitivesafet y r eports and

Airport Tower operat ing times

The safety object ives wil l need t o be inc luded in the Airport Dist rict Managerrsquos st atem ent of policy and objectives and then communicated to all of the organization They should be no diff erent f rom other organizationalobjectives in that they should be

Specific and measurable

Achiev able and challenging and

Realized within a specific t im e fram e

Mor especif ic saf ety object ivesapplicable to KOA will be d eveloped during Phase2 of the SMS pilot project

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8

III SAFETY ORGANIZATION

Key Featu res

The FAASOW f or SMS describes the follow ing requirem ent related to t hesafety organizat ion

An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel such as the following

Top Ma na gement

Saf ety Manager

Depart ment HeadsManagers

Established Saf ety Com mittees and Chairpersons

The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety The key feat ures descr ibed in the Advisory Cir cular ar eas follows

SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent) onewith t heaut hority to adequately c ontrolr esources beassigned SMSr esponsibil it ies

Defined saf ety authorities and responsibil ities f or allkey personnel that are assigned to the air port

Ident if icat ion within the system of som eoner esponsible for adm inistr ation of the overall SMS Often that one responsible person wil l be t he Safety Manager This person report s to the highest level of managem ent to assur eappr opriate consider ation of all repor ts r ecomm endations and issues

At m any air por ts oper ationsm ay support the Safety Manager being af ull-time perm anent employ ee and in som ecases having a support st aff

The responsibil ities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within theor ganizat ion

Depending on the s ize and com plex ity of the air por trsquos oper ation it may be useful to establish an Air port Safet y Committee (ASC) The safety committ ee ac ts as asource of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager

The SMS should also address how and to what extent t enants at t he airport such as the air lines fuel ing companies and ground handler s are integr ated into the airport SMS ICAO has m ade very strong ref erence to the inclusion of t enants at an airport ICAOrsquos Safet y Managem ent Manual Doc 9859 A460 Fir st Edition ndash 2006 chapter 18 ndashAER ODROME OPERATIONS statest hat

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Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

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The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

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The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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1 2

Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

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Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

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17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

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23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

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a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

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13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

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Appendix B

Safety Issues

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Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

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Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Safety Training and Communication

Gaps include

o SMS training

o Av iat ion safet y pr ograms

Phase 2 will dev elop the SMS based on the gaps identif ied

During the Gap Analysis J acobs Consultancy also made a num ber of observations on existing prac tic es and policies curr ently required under FARs Part 139 Not necessar ily part of an SMS these observations for considerat ion by KOA and HDOT-A are as follows

The HDOT-A should consider making the wearing of safety vests mandatory for all personnel working on the AOA

HDOT-A should consider am ore structured Enfor cement Progr am for specif ied airsid e safety violat ions

HDOT-A should strengthen the training funct ion at KOA and HDOT-A t o ensur e suf fic ient resources are availab le

Existing tr aining at KOA should be augmented with material from the FAA and other sources such as the American Association of Airport Exec ut ives

ARFF per sonnel should be tr ained to conduct inspections of all f ueling oper ations on the air port

HDOT-A should develop and pr ovide a training module in inspection tec hniques

During Jac obs Consultancy rsquos visits to KOA a number of issues were ident if ied that have the pot ential to impact the safety of passengers air por t employ ees or dam age equipment These issues should be reviewed by KOA the Air por t Safety Comm ittee and Saf ety Risk Managem ent as part of the SMS proc ess The SMS Manual w il l descr ibe these pr ocesses These issues wil l also be used for SMS training purposes The issues outlined in Appendix B of t his r epor t ar e as f ollows

Ramp congestion part icularly with increasing t raff ic volumes

Operations at the commuter ter minal

Fueling operations and the lack of fuel st orage capacity and

Very rough terr ain due t o lava fields outs ide of the graded runway safety ar eas

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I INTRODUCTION

Background

In Februar y 2007 the FAA issued Advisory Circular AC 1505200-37 Int roduction to Safety Managem ent Systems (SMS) for Airport Operator s t o introduce the concepts of SMS The F AA has also opened ar ulem aking project to consider f ormal requir ements for SMS at certified airports In support of t his rulemaking effort the FAA has init iat ed a pilot pr ogram to ass ist airpor ts in the developm ent of an SMS specif ic to their sit uation and operat ions and t o shar e their acquired exper ienc e on SMS dev elopm ent and implement ation with other airports and the FAA

The Hawaii Depar tment of Tr ansport ation Air por ts Divis ion (HDOT-A) has dec ided to take a leadership role in the development and im plem entation of SMS at the Kona Internat ional Air port at Keahole (KOA) by part icipating in the FAA pilot program

As part of t he pilot program HDOT-A has r etained the services of Jacobs Consult ancy t o provide consult ing ser vic es to develop a Saf ety Managem ent System (SMS) Program f or KOA

Ob jectives

The specific objectives and deliv erables of t heSMS dev elopment pr oject include

1 AGap Analysis The gap analys is wil l ident ify procedur espolicies doc um entat ionand actions that HDOT-Aand K OA need t o implement as par t of its SMSt hat go beyond the current Par t 139 r equir ements

2 A Draf t Plan A draft of t he com plete SMS Manual and Program Plan

3 The Final Plan The final copy of SMS Manual and Progr am Plan ready f or implement ation by KOA and HDOT-A The FAArsquos requirem ents for the Gap Analysis SMS Manual and Progr am Plan are included in Appendix A

4 Training of KOA and HDOT-A Divis ional employees in SMS

This repor t addresses t he Gap Analys is Phase 2 of t he SMS pr oject wil l develop the SMS for KOA and document it in an SMS Manual and Progr am Plan

The Gap Analys is addr esses what needs to be developed and im plem ented beyond the requirem ents of current Part 139 Our analy sis was not an audit of existing KOA polic ies and procedures as t o their adequacy completeness or c ompliance wit h Par t 139 requirem ents This is t hesubject of detai led F AAc er tification audits which is well beyond t hescopeof this project However based on our review of document ation and discussions wit h KOA and HDOT-A managers we have added in the r eport where appropriate a number of obser vations on ex ist ing practices and policies for considerat ion by HDOT-A Dur ing Jacobs Consult ancyrsquos visits to KOA a number of issues were also identified that have the potential to impact the safet y of passenger s air port em ployees or damage equipm ent These issues should be reviewed by KOA the Airport Safety Committee and Saf ety Risk Managem ent as part of the SMS pr oc ess The SMS Manual wil l describe t hese processes These issues wil l also be used for SMSt raining pur poses The issues are outlined in Appendix B

Methodology Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

1

Jac obs Consultancy pr epared the Gap Analy sis based on

Relevant FAA documentation including

Advisor y Circular AC 150 5200-37 February 2007

TheDraf t Statem ent of Work (SOW) for t heSMS Airport Pilot St udy

Relevant HDOT-A and KOA documentat ion

Selected inter views w it h HDOT-A Div ision manager s and KOAm anagers and supervisors

Guidelines regarding SMS from theInter national Civi l Av iation Organization (ICAO) and

The consult ing team rsquos exper ience wit h t he preparation of SMSf or other air ports

Operations at KOA

Kona Internat ional Airport at Keahole (KOA) is located on the luxurious Kona Gold Coast of West Hawaii KOA is operat ed by the Stat e of Hawaiirsquos Departm ent of Tr ansportation Air ports Div is ion and occupies 4204 acr es of land 9 miles northwest of the central business distr ict of KailuaKona The single story open-air set of terminal st ructur es is locat ed on the eastern edge of the airport and accomm odates domestic overseas inter national inter-island c om muterair t axi and general aviation activities Kona Internationalrsquos daily operations include a wide r ange of air craft such as CRJ-200 B-767 B-737 B-757 B-717 B-777 and B-747 aircraft from m any domest ic and inter national air car riers as well as general aviat ion and US mil itary airc raft In 2006 there were 143411 operations3033000 passengers 23900 tons of cargo and 8512 tons of mail

The Airport has an 11000-f oot r unway and a com plex of f acilities at t he sout hern edge of the airf ield f or air car go and mail air por t suppor t and general aviat ion operations An additional complex of facilit ies used primar ily by rental car agencies f or r eturns gener al maintenance and storage is located along the air port access r oadway midway between the passenger terminals and the main highway General aviation cargo and related fac ilit ies are located to t hesouth of the passenger terminalsand the access roadway

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Stru cture o f the Gap An alysi s

The Gap Analys is is s tructur ed to addr ess the f our element s of an SMS as out lined in the F AArsquos Advisory Circular As well we have added a separate element for Safet y Organization which t he Advisory Circular descr ibed under Safety Policy and Objectives In previous FAA pilot pr oject s that we conducted the FAA SMS Progr am Of ficeagr eed t o t his st ructur e

1 Safet y Polic ies and Objectives

2 Safet y Organization

3 Safet y Risk Managem ent

4 Safet y Assurance

5 Safet y Pr omotion

Under each of these five element s the Gap Analysis addresses t he FAArsquos detailed SMS Program content outlined in the FAA Advisor y Circular AC 1505200-37 and the F AA Draft St atem ent of Wor k (Appendix A)

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stemJT71 5500

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Gap An a Kona Inte rnational Airpo rt at Keahole Safety Management Sy

JT

Mor especif ical ly f or each element the Gap Analysis

1 Summ arizes the F AArsquos SMS guidance doc um entat ion internat ional guidance m ater ial where appropriate and J acobrsquos Consultancy Team rsquos SMS experience

2 Describes what systems policies and practices ex ist at KOA and then

3 Ident if ies procedures policies object ives organizational issues and document ation (ie Gaps) that need to be developed for SMS and how they will be addr essed in t he subsequent tasks to develop the SMS Manualand Saf ety Program Plan

Intent of SMS

The intent of SMS is t o im prove aviation safety The elimination of av iat ion acc idents is a desir able goal However no human activity or human-made syst em can be guar anteed t o be absolutely safe Failur es and err ors will occur in spite of best eff orts to avoid them Alt hough major air disasters are rare events less cat astrophic accident s and a whole rangeof incidents occur more fr equently Ignor ing these underlying saf ety hazar ds could pot entially pave the way for an inc rease in t he number of more serious accidents

The air transportat ion indust ryrsquos future viabilit y may well be pr ed icat ed on its ability to sust ain the publicrsquos perceived safety while traveling The m anagement of safety is therefore a pr erequisite for a sustainable aviation business

The accident rate in t he air transport industry has decreased dram atically between t he early 60rsquos and t hem id 80rsquos from 30 to near 2 per mill ion departures It could be easily argued t hat this rate was achieved f rom continuing efforts by the industry t o m akeair tr avela saf em odeof tr ansport ation But as the following diagram illustr ates bet ween the mid eighties and now we find an 80 incr ease in air tr aff ic and a 73 inc rease in the number of accidents Alt hough the accident rate per mill ion departures rem ains st eady at 2 air tr avel saf ety as perceived by thepublic is l ikely to dec line if traf fic gr owt h and accident rate per million depart ures rem ain the sam e Air t ravel relat ed accidents make instant worldwide news and there will be m ore and more reports even while maintaining a relat ively low accident rat e Safet y m anagement when well in p lace within the industry wil l be a key f actor in f urther reducing the accident r ate and achieving act ual and perceived impr ov ement in aviation s afety

7155 00

4 ly si s stem

Sou rce In tern a l Jacobs Con su ltancy for illu stra tive p u rpose s

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II SAFETY POLICIES AND OBJECTIVES

Key Featu res

The FAASOW f or SMS stat es that Safety Policies and Object ives should include

Written saf ety policy stat ement (s) and a descr iption of how it is communicat ed to airport em ployees and

Ident if icat ion and description of the air port saf ety goals

The FAA Adv isor y Circular under Saf ety Policy indic ates that managem entrsquos c ommitm ent to safety should be formally expr essed in a stat ement of safety policy t hat reflects theairpor trsquossafety philosophy and that iss igned by Top Management

Key attr ibutes of t hepolicy could also include the following

The commitm ent of senior m anagem ent to implem ent SMS

Stat es the air portrsquos intentions management princ iples and comm it ment to continuous improvement to safety at the air port

Is com municated to all employ ees

Is implemented at al l levels of the airport

Confir ms that safet y is every onersquos responsibil ity and

Recognizes that there will alway s be threats to safety and that the air port will provide the highest reasonable standard of safety The Advisory Cir cular refers to a comm it ment to make safet y t he highest priorit y which m ay have adiff erent meaning

The Adv isor y Circular under Safet y Objectives ( Section 222) does not address object ives but deals w it h the organization f or safety The Advisory Circular does r efer to safety perform ance indicat ors and tar gets under Saf ety Assurance ( Section 24)

SMS guidelines inc luding the FAA Advisory Circular g ive very l it tle practical advice on safety goals or objectives The t erms ldquogoalsrdquo and ldquoobjectives rdquo as well as ldquotargets rdquo are frequently used interchangeably The intent in the guidelines nonetheless is to have measurableindicators of safety

Existing Poli cies an d Objectives

HDOT-A has an Em ployee Safet y and Health Pr ogram which is based primarily on the r equir ements of the Hawaii Occupational Safety and Health (HIOSH) standards for the benefit and general welfare of HDOT-A em ployees HDOT-Arsquos occupational saf ety and health st ated policy is t o provide a safe accident-free and healthy wor kenvironm ent for its employees in ar eas such as

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Personal Pr otect ive Equipment (PPE)

Respiratory Pr otection

Hazardous Wast eOperat ions

Noise Exposure

Hazard Communication

Biological Agent s SARSBlood borne Pathogens

Confined Space and

Vio lence in the Wor kplac e

The Employee Health and Safet y Program is not direct ly related to air side aviation safety which is t he intent of SMS

HDOT-A does not currently have a writt en saf ety policy endorsed by Senior Exec ut ive (Top Managem ent) to indicat et heir com mitment t o aviation safet y which is a key element of an SMS

Gaps and Developmen t Required

Safety Policies

Phase 2 of theSMS project wi ll need to develop and docum ent aviation safety policies that should be endorsed by HDOT-A

Note In the developm ent of SMS som e airports have consider ed com bining SMS and employee safety in one document Initial comm ents from HDOT-A managem ent have also suggested that this integrat ion be considered However one docum ent wil l likely not be feasible or pract icable Jacobs Consultancy discussions wit h the FAA have indicated that SMS will event ually be part of the Airport Cer tification Manual (ACM) in the fut ure and that they are not interest ed or concerned with Occupational Saf ety and Health Issues or requirem ents Requirem ents by t he Hawaii Occupational and Health and by the F AA are not the sam e (for exam ple r eporting and risk analyses differ ) Although one safet y docum ent is not pr acticable we do believe that wit hin t he KOA and HDOT-A organiz ation t hose cur rently involved in safety could pot entia lly also be involved in SMS f or example a safet y of fice or off ic er that addresses both SMS and HIOSH requirem ents This organization ar rangem ent will be considered further in t he subsequent Phase 2 of this project to develop the SMS

Safety Objectives

Saf ety objectives are also requir ed to allow for assessm ent of saf ety performance and developments at the airport Safet y objectives should be linked to f actor s such as

Safety hazards identified during inspections eg type and quantity of FOD (Not e the airport rsquos self-inspect ion program captur es this infor mat ion but does not systematically monitor tr ends in this information)

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

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Airs id e safety violations

Aircr aft bird strikes

Incurs ions of vehicles aircraf tor pedest rians on movement ar eas

Ac cidents and incident s on the AOA andor the contr olled m ov ement area involving air carr ier aircraft andor ground v ehicles

Oper able time of lighting systems

Number of airs ide based employees who have received safety and SMSr elat ed t raining

Non-punitivesafet y r eports and

Airport Tower operat ing times

The safety object ives wil l need t o be inc luded in the Airport Dist rict Managerrsquos st atem ent of policy and objectives and then communicated to all of the organization They should be no diff erent f rom other organizationalobjectives in that they should be

Specific and measurable

Achiev able and challenging and

Realized within a specific t im e fram e

Mor especif ic saf ety object ivesapplicable to KOA will be d eveloped during Phase2 of the SMS pilot project

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III SAFETY ORGANIZATION

Key Featu res

The FAASOW f or SMS describes the follow ing requirem ent related to t hesafety organizat ion

An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel such as the following

Top Ma na gement

Saf ety Manager

Depart ment HeadsManagers

Established Saf ety Com mittees and Chairpersons

The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety The key feat ures descr ibed in the Advisory Cir cular ar eas follows

SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent) onewith t heaut hority to adequately c ontrolr esources beassigned SMSr esponsibil it ies

Defined saf ety authorities and responsibil ities f or allkey personnel that are assigned to the air port

Ident if icat ion within the system of som eoner esponsible for adm inistr ation of the overall SMS Often that one responsible person wil l be t he Safety Manager This person report s to the highest level of managem ent to assur eappr opriate consider ation of all repor ts r ecomm endations and issues

At m any air por ts oper ationsm ay support the Safety Manager being af ull-time perm anent employ ee and in som ecases having a support st aff

The responsibil ities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within theor ganizat ion

Depending on the s ize and com plex ity of the air por trsquos oper ation it may be useful to establish an Air port Safet y Committee (ASC) The safety committ ee ac ts as asource of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager

The SMS should also address how and to what extent t enants at t he airport such as the air lines fuel ing companies and ground handler s are integr ated into the airport SMS ICAO has m ade very strong ref erence to the inclusion of t enants at an airport ICAOrsquos Safet y Managem ent Manual Doc 9859 A460 Fir st Edition ndash 2006 chapter 18 ndashAER ODROME OPERATIONS statest hat

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Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

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The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

Gap Analy sis 11 KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

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Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

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17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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1 8

IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

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23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

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Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

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C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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Appendix D

Examples of Safety and Security Enforcement Programs

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Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

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Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

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Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

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Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

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Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

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I INTRODUCTION

Background

In Februar y 2007 the FAA issued Advisory Circular AC 1505200-37 Int roduction to Safety Managem ent Systems (SMS) for Airport Operator s t o introduce the concepts of SMS The F AA has also opened ar ulem aking project to consider f ormal requir ements for SMS at certified airports In support of t his rulemaking effort the FAA has init iat ed a pilot pr ogram to ass ist airpor ts in the developm ent of an SMS specif ic to their sit uation and operat ions and t o shar e their acquired exper ienc e on SMS dev elopm ent and implement ation with other airports and the FAA

The Hawaii Depar tment of Tr ansport ation Air por ts Divis ion (HDOT-A) has dec ided to take a leadership role in the development and im plem entation of SMS at the Kona Internat ional Air port at Keahole (KOA) by part icipating in the FAA pilot program

As part of t he pilot program HDOT-A has r etained the services of Jacobs Consult ancy t o provide consult ing ser vic es to develop a Saf ety Managem ent System (SMS) Program f or KOA

Ob jectives

The specific objectives and deliv erables of t heSMS dev elopment pr oject include

1 AGap Analysis The gap analys is wil l ident ify procedur espolicies doc um entat ionand actions that HDOT-Aand K OA need t o implement as par t of its SMSt hat go beyond the current Par t 139 r equir ements

2 A Draf t Plan A draft of t he com plete SMS Manual and Program Plan

3 The Final Plan The final copy of SMS Manual and Progr am Plan ready f or implement ation by KOA and HDOT-A The FAArsquos requirem ents for the Gap Analysis SMS Manual and Progr am Plan are included in Appendix A

4 Training of KOA and HDOT-A Divis ional employees in SMS

This repor t addresses t he Gap Analys is Phase 2 of t he SMS pr oject wil l develop the SMS for KOA and document it in an SMS Manual and Progr am Plan

The Gap Analys is addr esses what needs to be developed and im plem ented beyond the requirem ents of current Part 139 Our analy sis was not an audit of existing KOA polic ies and procedures as t o their adequacy completeness or c ompliance wit h Par t 139 requirem ents This is t hesubject of detai led F AAc er tification audits which is well beyond t hescopeof this project However based on our review of document ation and discussions wit h KOA and HDOT-A managers we have added in the r eport where appropriate a number of obser vations on ex ist ing practices and policies for considerat ion by HDOT-A Dur ing Jacobs Consult ancyrsquos visits to KOA a number of issues were also identified that have the potential to impact the safet y of passenger s air port em ployees or damage equipm ent These issues should be reviewed by KOA the Airport Safety Committee and Saf ety Risk Managem ent as part of the SMS pr oc ess The SMS Manual wil l describe t hese processes These issues wil l also be used for SMSt raining pur poses The issues are outlined in Appendix B

Methodology Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

1

Jac obs Consultancy pr epared the Gap Analy sis based on

Relevant FAA documentation including

Advisor y Circular AC 150 5200-37 February 2007

TheDraf t Statem ent of Work (SOW) for t heSMS Airport Pilot St udy

Relevant HDOT-A and KOA documentat ion

Selected inter views w it h HDOT-A Div ision manager s and KOAm anagers and supervisors

Guidelines regarding SMS from theInter national Civi l Av iation Organization (ICAO) and

The consult ing team rsquos exper ience wit h t he preparation of SMSf or other air ports

Operations at KOA

Kona Internat ional Airport at Keahole (KOA) is located on the luxurious Kona Gold Coast of West Hawaii KOA is operat ed by the Stat e of Hawaiirsquos Departm ent of Tr ansportation Air ports Div is ion and occupies 4204 acr es of land 9 miles northwest of the central business distr ict of KailuaKona The single story open-air set of terminal st ructur es is locat ed on the eastern edge of the airport and accomm odates domestic overseas inter national inter-island c om muterair t axi and general aviation activities Kona Internationalrsquos daily operations include a wide r ange of air craft such as CRJ-200 B-767 B-737 B-757 B-717 B-777 and B-747 aircraft from m any domest ic and inter national air car riers as well as general aviat ion and US mil itary airc raft In 2006 there were 143411 operations3033000 passengers 23900 tons of cargo and 8512 tons of mail

The Airport has an 11000-f oot r unway and a com plex of f acilities at t he sout hern edge of the airf ield f or air car go and mail air por t suppor t and general aviat ion operations An additional complex of facilit ies used primar ily by rental car agencies f or r eturns gener al maintenance and storage is located along the air port access r oadway midway between the passenger terminals and the main highway General aviation cargo and related fac ilit ies are located to t hesouth of the passenger terminalsand the access roadway

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2

Stru cture o f the Gap An alysi s

The Gap Analys is is s tructur ed to addr ess the f our element s of an SMS as out lined in the F AArsquos Advisory Circular As well we have added a separate element for Safet y Organization which t he Advisory Circular descr ibed under Safety Policy and Objectives In previous FAA pilot pr oject s that we conducted the FAA SMS Progr am Of ficeagr eed t o t his st ructur e

1 Safet y Polic ies and Objectives

2 Safet y Organization

3 Safet y Risk Managem ent

4 Safet y Assurance

5 Safet y Pr omotion

Under each of these five element s the Gap Analysis addresses t he FAArsquos detailed SMS Program content outlined in the FAA Advisor y Circular AC 1505200-37 and the F AA Draft St atem ent of Wor k (Appendix A)

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stemJT71 5500

3

Gap An a Kona Inte rnational Airpo rt at Keahole Safety Management Sy

JT

Mor especif ical ly f or each element the Gap Analysis

1 Summ arizes the F AArsquos SMS guidance doc um entat ion internat ional guidance m ater ial where appropriate and J acobrsquos Consultancy Team rsquos SMS experience

2 Describes what systems policies and practices ex ist at KOA and then

3 Ident if ies procedures policies object ives organizational issues and document ation (ie Gaps) that need to be developed for SMS and how they will be addr essed in t he subsequent tasks to develop the SMS Manualand Saf ety Program Plan

Intent of SMS

The intent of SMS is t o im prove aviation safety The elimination of av iat ion acc idents is a desir able goal However no human activity or human-made syst em can be guar anteed t o be absolutely safe Failur es and err ors will occur in spite of best eff orts to avoid them Alt hough major air disasters are rare events less cat astrophic accident s and a whole rangeof incidents occur more fr equently Ignor ing these underlying saf ety hazar ds could pot entially pave the way for an inc rease in t he number of more serious accidents

The air transportat ion indust ryrsquos future viabilit y may well be pr ed icat ed on its ability to sust ain the publicrsquos perceived safety while traveling The m anagement of safety is therefore a pr erequisite for a sustainable aviation business

The accident rate in t he air transport industry has decreased dram atically between t he early 60rsquos and t hem id 80rsquos from 30 to near 2 per mill ion departures It could be easily argued t hat this rate was achieved f rom continuing efforts by the industry t o m akeair tr avela saf em odeof tr ansport ation But as the following diagram illustr ates bet ween the mid eighties and now we find an 80 incr ease in air tr aff ic and a 73 inc rease in the number of accidents Alt hough the accident rate per mill ion departures rem ains st eady at 2 air tr avel saf ety as perceived by thepublic is l ikely to dec line if traf fic gr owt h and accident rate per million depart ures rem ain the sam e Air t ravel relat ed accidents make instant worldwide news and there will be m ore and more reports even while maintaining a relat ively low accident rat e Safet y m anagement when well in p lace within the industry wil l be a key f actor in f urther reducing the accident r ate and achieving act ual and perceived impr ov ement in aviation s afety

7155 00

4 ly si s stem

Sou rce In tern a l Jacobs Con su ltancy for illu stra tive p u rpose s

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5

II SAFETY POLICIES AND OBJECTIVES

Key Featu res

The FAASOW f or SMS stat es that Safety Policies and Object ives should include

Written saf ety policy stat ement (s) and a descr iption of how it is communicat ed to airport em ployees and

Ident if icat ion and description of the air port saf ety goals

The FAA Adv isor y Circular under Saf ety Policy indic ates that managem entrsquos c ommitm ent to safety should be formally expr essed in a stat ement of safety policy t hat reflects theairpor trsquossafety philosophy and that iss igned by Top Management

Key attr ibutes of t hepolicy could also include the following

The commitm ent of senior m anagem ent to implem ent SMS

Stat es the air portrsquos intentions management princ iples and comm it ment to continuous improvement to safety at the air port

Is com municated to all employ ees

Is implemented at al l levels of the airport

Confir ms that safet y is every onersquos responsibil ity and

Recognizes that there will alway s be threats to safety and that the air port will provide the highest reasonable standard of safety The Advisory Cir cular refers to a comm it ment to make safet y t he highest priorit y which m ay have adiff erent meaning

The Adv isor y Circular under Safet y Objectives ( Section 222) does not address object ives but deals w it h the organization f or safety The Advisory Circular does r efer to safety perform ance indicat ors and tar gets under Saf ety Assurance ( Section 24)

SMS guidelines inc luding the FAA Advisory Circular g ive very l it tle practical advice on safety goals or objectives The t erms ldquogoalsrdquo and ldquoobjectives rdquo as well as ldquotargets rdquo are frequently used interchangeably The intent in the guidelines nonetheless is to have measurableindicators of safety

Existing Poli cies an d Objectives

HDOT-A has an Em ployee Safet y and Health Pr ogram which is based primarily on the r equir ements of the Hawaii Occupational Safety and Health (HIOSH) standards for the benefit and general welfare of HDOT-A em ployees HDOT-Arsquos occupational saf ety and health st ated policy is t o provide a safe accident-free and healthy wor kenvironm ent for its employees in ar eas such as

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

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6

Personal Pr otect ive Equipment (PPE)

Respiratory Pr otection

Hazardous Wast eOperat ions

Noise Exposure

Hazard Communication

Biological Agent s SARSBlood borne Pathogens

Confined Space and

Vio lence in the Wor kplac e

The Employee Health and Safet y Program is not direct ly related to air side aviation safety which is t he intent of SMS

HDOT-A does not currently have a writt en saf ety policy endorsed by Senior Exec ut ive (Top Managem ent) to indicat et heir com mitment t o aviation safet y which is a key element of an SMS

Gaps and Developmen t Required

Safety Policies

Phase 2 of theSMS project wi ll need to develop and docum ent aviation safety policies that should be endorsed by HDOT-A

Note In the developm ent of SMS som e airports have consider ed com bining SMS and employee safety in one document Initial comm ents from HDOT-A managem ent have also suggested that this integrat ion be considered However one docum ent wil l likely not be feasible or pract icable Jacobs Consultancy discussions wit h the FAA have indicated that SMS will event ually be part of the Airport Cer tification Manual (ACM) in the fut ure and that they are not interest ed or concerned with Occupational Saf ety and Health Issues or requirem ents Requirem ents by t he Hawaii Occupational and Health and by the F AA are not the sam e (for exam ple r eporting and risk analyses differ ) Although one safet y docum ent is not pr acticable we do believe that wit hin t he KOA and HDOT-A organiz ation t hose cur rently involved in safety could pot entia lly also be involved in SMS f or example a safet y of fice or off ic er that addresses both SMS and HIOSH requirem ents This organization ar rangem ent will be considered further in t he subsequent Phase 2 of this project to develop the SMS

Safety Objectives

Saf ety objectives are also requir ed to allow for assessm ent of saf ety performance and developments at the airport Safet y objectives should be linked to f actor s such as

Safety hazards identified during inspections eg type and quantity of FOD (Not e the airport rsquos self-inspect ion program captur es this infor mat ion but does not systematically monitor tr ends in this information)

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

7

Airs id e safety violations

Aircr aft bird strikes

Incurs ions of vehicles aircraf tor pedest rians on movement ar eas

Ac cidents and incident s on the AOA andor the contr olled m ov ement area involving air carr ier aircraft andor ground v ehicles

Oper able time of lighting systems

Number of airs ide based employees who have received safety and SMSr elat ed t raining

Non-punitivesafet y r eports and

Airport Tower operat ing times

The safety object ives wil l need t o be inc luded in the Airport Dist rict Managerrsquos st atem ent of policy and objectives and then communicated to all of the organization They should be no diff erent f rom other organizationalobjectives in that they should be

Specific and measurable

Achiev able and challenging and

Realized within a specific t im e fram e

Mor especif ic saf ety object ivesapplicable to KOA will be d eveloped during Phase2 of the SMS pilot project

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8

III SAFETY ORGANIZATION

Key Featu res

The FAASOW f or SMS describes the follow ing requirem ent related to t hesafety organizat ion

An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel such as the following

Top Ma na gement

Saf ety Manager

Depart ment HeadsManagers

Established Saf ety Com mittees and Chairpersons

The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety The key feat ures descr ibed in the Advisory Cir cular ar eas follows

SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent) onewith t heaut hority to adequately c ontrolr esources beassigned SMSr esponsibil it ies

Defined saf ety authorities and responsibil ities f or allkey personnel that are assigned to the air port

Ident if icat ion within the system of som eoner esponsible for adm inistr ation of the overall SMS Often that one responsible person wil l be t he Safety Manager This person report s to the highest level of managem ent to assur eappr opriate consider ation of all repor ts r ecomm endations and issues

At m any air por ts oper ationsm ay support the Safety Manager being af ull-time perm anent employ ee and in som ecases having a support st aff

The responsibil ities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within theor ganizat ion

Depending on the s ize and com plex ity of the air por trsquos oper ation it may be useful to establish an Air port Safet y Committee (ASC) The safety committ ee ac ts as asource of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager

The SMS should also address how and to what extent t enants at t he airport such as the air lines fuel ing companies and ground handler s are integr ated into the airport SMS ICAO has m ade very strong ref erence to the inclusion of t enants at an airport ICAOrsquos Safet y Managem ent Manual Doc 9859 A460 Fir st Edition ndash 2006 chapter 18 ndashAER ODROME OPERATIONS statest hat

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

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Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

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1 0

The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

Gap Analy sis 11 KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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1 2

Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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1 4

AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

1 6

Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

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17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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1 8

IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

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23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

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25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Jac obs Consultancy pr epared the Gap Analy sis based on

Relevant FAA documentation including

Advisor y Circular AC 150 5200-37 February 2007

TheDraf t Statem ent of Work (SOW) for t heSMS Airport Pilot St udy

Relevant HDOT-A and KOA documentat ion

Selected inter views w it h HDOT-A Div ision manager s and KOAm anagers and supervisors

Guidelines regarding SMS from theInter national Civi l Av iation Organization (ICAO) and

The consult ing team rsquos exper ience wit h t he preparation of SMSf or other air ports

Operations at KOA

Kona Internat ional Airport at Keahole (KOA) is located on the luxurious Kona Gold Coast of West Hawaii KOA is operat ed by the Stat e of Hawaiirsquos Departm ent of Tr ansportation Air ports Div is ion and occupies 4204 acr es of land 9 miles northwest of the central business distr ict of KailuaKona The single story open-air set of terminal st ructur es is locat ed on the eastern edge of the airport and accomm odates domestic overseas inter national inter-island c om muterair t axi and general aviation activities Kona Internationalrsquos daily operations include a wide r ange of air craft such as CRJ-200 B-767 B-737 B-757 B-717 B-777 and B-747 aircraft from m any domest ic and inter national air car riers as well as general aviat ion and US mil itary airc raft In 2006 there were 143411 operations3033000 passengers 23900 tons of cargo and 8512 tons of mail

The Airport has an 11000-f oot r unway and a com plex of f acilities at t he sout hern edge of the airf ield f or air car go and mail air por t suppor t and general aviat ion operations An additional complex of facilit ies used primar ily by rental car agencies f or r eturns gener al maintenance and storage is located along the air port access r oadway midway between the passenger terminals and the main highway General aviation cargo and related fac ilit ies are located to t hesouth of the passenger terminalsand the access roadway

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

JT 7155 00

2

Stru cture o f the Gap An alysi s

The Gap Analys is is s tructur ed to addr ess the f our element s of an SMS as out lined in the F AArsquos Advisory Circular As well we have added a separate element for Safet y Organization which t he Advisory Circular descr ibed under Safety Policy and Objectives In previous FAA pilot pr oject s that we conducted the FAA SMS Progr am Of ficeagr eed t o t his st ructur e

1 Safet y Polic ies and Objectives

2 Safet y Organization

3 Safet y Risk Managem ent

4 Safet y Assurance

5 Safet y Pr omotion

Under each of these five element s the Gap Analysis addresses t he FAArsquos detailed SMS Program content outlined in the FAA Advisor y Circular AC 1505200-37 and the F AA Draft St atem ent of Wor k (Appendix A)

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stemJT71 5500

3

Gap An a Kona Inte rnational Airpo rt at Keahole Safety Management Sy

JT

Mor especif ical ly f or each element the Gap Analysis

1 Summ arizes the F AArsquos SMS guidance doc um entat ion internat ional guidance m ater ial where appropriate and J acobrsquos Consultancy Team rsquos SMS experience

2 Describes what systems policies and practices ex ist at KOA and then

3 Ident if ies procedures policies object ives organizational issues and document ation (ie Gaps) that need to be developed for SMS and how they will be addr essed in t he subsequent tasks to develop the SMS Manualand Saf ety Program Plan

Intent of SMS

The intent of SMS is t o im prove aviation safety The elimination of av iat ion acc idents is a desir able goal However no human activity or human-made syst em can be guar anteed t o be absolutely safe Failur es and err ors will occur in spite of best eff orts to avoid them Alt hough major air disasters are rare events less cat astrophic accident s and a whole rangeof incidents occur more fr equently Ignor ing these underlying saf ety hazar ds could pot entially pave the way for an inc rease in t he number of more serious accidents

The air transportat ion indust ryrsquos future viabilit y may well be pr ed icat ed on its ability to sust ain the publicrsquos perceived safety while traveling The m anagement of safety is therefore a pr erequisite for a sustainable aviation business

The accident rate in t he air transport industry has decreased dram atically between t he early 60rsquos and t hem id 80rsquos from 30 to near 2 per mill ion departures It could be easily argued t hat this rate was achieved f rom continuing efforts by the industry t o m akeair tr avela saf em odeof tr ansport ation But as the following diagram illustr ates bet ween the mid eighties and now we find an 80 incr ease in air tr aff ic and a 73 inc rease in the number of accidents Alt hough the accident rate per mill ion departures rem ains st eady at 2 air tr avel saf ety as perceived by thepublic is l ikely to dec line if traf fic gr owt h and accident rate per million depart ures rem ain the sam e Air t ravel relat ed accidents make instant worldwide news and there will be m ore and more reports even while maintaining a relat ively low accident rat e Safet y m anagement when well in p lace within the industry wil l be a key f actor in f urther reducing the accident r ate and achieving act ual and perceived impr ov ement in aviation s afety

7155 00

4 ly si s stem

Sou rce In tern a l Jacobs Con su ltancy for illu stra tive p u rpose s

Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

5

II SAFETY POLICIES AND OBJECTIVES

Key Featu res

The FAASOW f or SMS stat es that Safety Policies and Object ives should include

Written saf ety policy stat ement (s) and a descr iption of how it is communicat ed to airport em ployees and

Ident if icat ion and description of the air port saf ety goals

The FAA Adv isor y Circular under Saf ety Policy indic ates that managem entrsquos c ommitm ent to safety should be formally expr essed in a stat ement of safety policy t hat reflects theairpor trsquossafety philosophy and that iss igned by Top Management

Key attr ibutes of t hepolicy could also include the following

The commitm ent of senior m anagem ent to implem ent SMS

Stat es the air portrsquos intentions management princ iples and comm it ment to continuous improvement to safety at the air port

Is com municated to all employ ees

Is implemented at al l levels of the airport

Confir ms that safet y is every onersquos responsibil ity and

Recognizes that there will alway s be threats to safety and that the air port will provide the highest reasonable standard of safety The Advisory Cir cular refers to a comm it ment to make safet y t he highest priorit y which m ay have adiff erent meaning

The Adv isor y Circular under Safet y Objectives ( Section 222) does not address object ives but deals w it h the organization f or safety The Advisory Circular does r efer to safety perform ance indicat ors and tar gets under Saf ety Assurance ( Section 24)

SMS guidelines inc luding the FAA Advisory Circular g ive very l it tle practical advice on safety goals or objectives The t erms ldquogoalsrdquo and ldquoobjectives rdquo as well as ldquotargets rdquo are frequently used interchangeably The intent in the guidelines nonetheless is to have measurableindicators of safety

Existing Poli cies an d Objectives

HDOT-A has an Em ployee Safet y and Health Pr ogram which is based primarily on the r equir ements of the Hawaii Occupational Safety and Health (HIOSH) standards for the benefit and general welfare of HDOT-A em ployees HDOT-Arsquos occupational saf ety and health st ated policy is t o provide a safe accident-free and healthy wor kenvironm ent for its employees in ar eas such as

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

JT 7155 00

6

Personal Pr otect ive Equipment (PPE)

Respiratory Pr otection

Hazardous Wast eOperat ions

Noise Exposure

Hazard Communication

Biological Agent s SARSBlood borne Pathogens

Confined Space and

Vio lence in the Wor kplac e

The Employee Health and Safet y Program is not direct ly related to air side aviation safety which is t he intent of SMS

HDOT-A does not currently have a writt en saf ety policy endorsed by Senior Exec ut ive (Top Managem ent) to indicat et heir com mitment t o aviation safet y which is a key element of an SMS

Gaps and Developmen t Required

Safety Policies

Phase 2 of theSMS project wi ll need to develop and docum ent aviation safety policies that should be endorsed by HDOT-A

Note In the developm ent of SMS som e airports have consider ed com bining SMS and employee safety in one document Initial comm ents from HDOT-A managem ent have also suggested that this integrat ion be considered However one docum ent wil l likely not be feasible or pract icable Jacobs Consultancy discussions wit h the FAA have indicated that SMS will event ually be part of the Airport Cer tification Manual (ACM) in the fut ure and that they are not interest ed or concerned with Occupational Saf ety and Health Issues or requirem ents Requirem ents by t he Hawaii Occupational and Health and by the F AA are not the sam e (for exam ple r eporting and risk analyses differ ) Although one safet y docum ent is not pr acticable we do believe that wit hin t he KOA and HDOT-A organiz ation t hose cur rently involved in safety could pot entia lly also be involved in SMS f or example a safet y of fice or off ic er that addresses both SMS and HIOSH requirem ents This organization ar rangem ent will be considered further in t he subsequent Phase 2 of this project to develop the SMS

Safety Objectives

Saf ety objectives are also requir ed to allow for assessm ent of saf ety performance and developments at the airport Safet y objectives should be linked to f actor s such as

Safety hazards identified during inspections eg type and quantity of FOD (Not e the airport rsquos self-inspect ion program captur es this infor mat ion but does not systematically monitor tr ends in this information)

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7

Airs id e safety violations

Aircr aft bird strikes

Incurs ions of vehicles aircraf tor pedest rians on movement ar eas

Ac cidents and incident s on the AOA andor the contr olled m ov ement area involving air carr ier aircraft andor ground v ehicles

Oper able time of lighting systems

Number of airs ide based employees who have received safety and SMSr elat ed t raining

Non-punitivesafet y r eports and

Airport Tower operat ing times

The safety object ives wil l need t o be inc luded in the Airport Dist rict Managerrsquos st atem ent of policy and objectives and then communicated to all of the organization They should be no diff erent f rom other organizationalobjectives in that they should be

Specific and measurable

Achiev able and challenging and

Realized within a specific t im e fram e

Mor especif ic saf ety object ivesapplicable to KOA will be d eveloped during Phase2 of the SMS pilot project

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III SAFETY ORGANIZATION

Key Featu res

The FAASOW f or SMS describes the follow ing requirem ent related to t hesafety organizat ion

An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel such as the following

Top Ma na gement

Saf ety Manager

Depart ment HeadsManagers

Established Saf ety Com mittees and Chairpersons

The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety The key feat ures descr ibed in the Advisory Cir cular ar eas follows

SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent) onewith t heaut hority to adequately c ontrolr esources beassigned SMSr esponsibil it ies

Defined saf ety authorities and responsibil ities f or allkey personnel that are assigned to the air port

Ident if icat ion within the system of som eoner esponsible for adm inistr ation of the overall SMS Often that one responsible person wil l be t he Safety Manager This person report s to the highest level of managem ent to assur eappr opriate consider ation of all repor ts r ecomm endations and issues

At m any air por ts oper ationsm ay support the Safety Manager being af ull-time perm anent employ ee and in som ecases having a support st aff

The responsibil ities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within theor ganizat ion

Depending on the s ize and com plex ity of the air por trsquos oper ation it may be useful to establish an Air port Safet y Committee (ASC) The safety committ ee ac ts as asource of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager

The SMS should also address how and to what extent t enants at t he airport such as the air lines fuel ing companies and ground handler s are integr ated into the airport SMS ICAO has m ade very strong ref erence to the inclusion of t enants at an airport ICAOrsquos Safet y Managem ent Manual Doc 9859 A460 Fir st Edition ndash 2006 chapter 18 ndashAER ODROME OPERATIONS statest hat

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Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

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1 0

The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

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The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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1 2

Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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1 4

AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

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1 6

Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

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17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

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23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

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25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

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a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

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13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

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Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Stru cture o f the Gap An alysi s

The Gap Analys is is s tructur ed to addr ess the f our element s of an SMS as out lined in the F AArsquos Advisory Circular As well we have added a separate element for Safet y Organization which t he Advisory Circular descr ibed under Safety Policy and Objectives In previous FAA pilot pr oject s that we conducted the FAA SMS Progr am Of ficeagr eed t o t his st ructur e

1 Safet y Polic ies and Objectives

2 Safet y Organization

3 Safet y Risk Managem ent

4 Safet y Assurance

5 Safet y Pr omotion

Under each of these five element s the Gap Analysis addresses t he FAArsquos detailed SMS Program content outlined in the FAA Advisor y Circular AC 1505200-37 and the F AA Draft St atem ent of Wor k (Appendix A)

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stemJT71 5500

3

Gap An a Kona Inte rnational Airpo rt at Keahole Safety Management Sy

JT

Mor especif ical ly f or each element the Gap Analysis

1 Summ arizes the F AArsquos SMS guidance doc um entat ion internat ional guidance m ater ial where appropriate and J acobrsquos Consultancy Team rsquos SMS experience

2 Describes what systems policies and practices ex ist at KOA and then

3 Ident if ies procedures policies object ives organizational issues and document ation (ie Gaps) that need to be developed for SMS and how they will be addr essed in t he subsequent tasks to develop the SMS Manualand Saf ety Program Plan

Intent of SMS

The intent of SMS is t o im prove aviation safety The elimination of av iat ion acc idents is a desir able goal However no human activity or human-made syst em can be guar anteed t o be absolutely safe Failur es and err ors will occur in spite of best eff orts to avoid them Alt hough major air disasters are rare events less cat astrophic accident s and a whole rangeof incidents occur more fr equently Ignor ing these underlying saf ety hazar ds could pot entially pave the way for an inc rease in t he number of more serious accidents

The air transportat ion indust ryrsquos future viabilit y may well be pr ed icat ed on its ability to sust ain the publicrsquos perceived safety while traveling The m anagement of safety is therefore a pr erequisite for a sustainable aviation business

The accident rate in t he air transport industry has decreased dram atically between t he early 60rsquos and t hem id 80rsquos from 30 to near 2 per mill ion departures It could be easily argued t hat this rate was achieved f rom continuing efforts by the industry t o m akeair tr avela saf em odeof tr ansport ation But as the following diagram illustr ates bet ween the mid eighties and now we find an 80 incr ease in air tr aff ic and a 73 inc rease in the number of accidents Alt hough the accident rate per mill ion departures rem ains st eady at 2 air tr avel saf ety as perceived by thepublic is l ikely to dec line if traf fic gr owt h and accident rate per million depart ures rem ain the sam e Air t ravel relat ed accidents make instant worldwide news and there will be m ore and more reports even while maintaining a relat ively low accident rat e Safet y m anagement when well in p lace within the industry wil l be a key f actor in f urther reducing the accident r ate and achieving act ual and perceived impr ov ement in aviation s afety

7155 00

4 ly si s stem

Sou rce In tern a l Jacobs Con su ltancy for illu stra tive p u rpose s

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5

II SAFETY POLICIES AND OBJECTIVES

Key Featu res

The FAASOW f or SMS stat es that Safety Policies and Object ives should include

Written saf ety policy stat ement (s) and a descr iption of how it is communicat ed to airport em ployees and

Ident if icat ion and description of the air port saf ety goals

The FAA Adv isor y Circular under Saf ety Policy indic ates that managem entrsquos c ommitm ent to safety should be formally expr essed in a stat ement of safety policy t hat reflects theairpor trsquossafety philosophy and that iss igned by Top Management

Key attr ibutes of t hepolicy could also include the following

The commitm ent of senior m anagem ent to implem ent SMS

Stat es the air portrsquos intentions management princ iples and comm it ment to continuous improvement to safety at the air port

Is com municated to all employ ees

Is implemented at al l levels of the airport

Confir ms that safet y is every onersquos responsibil ity and

Recognizes that there will alway s be threats to safety and that the air port will provide the highest reasonable standard of safety The Advisory Cir cular refers to a comm it ment to make safet y t he highest priorit y which m ay have adiff erent meaning

The Adv isor y Circular under Safet y Objectives ( Section 222) does not address object ives but deals w it h the organization f or safety The Advisory Circular does r efer to safety perform ance indicat ors and tar gets under Saf ety Assurance ( Section 24)

SMS guidelines inc luding the FAA Advisory Circular g ive very l it tle practical advice on safety goals or objectives The t erms ldquogoalsrdquo and ldquoobjectives rdquo as well as ldquotargets rdquo are frequently used interchangeably The intent in the guidelines nonetheless is to have measurableindicators of safety

Existing Poli cies an d Objectives

HDOT-A has an Em ployee Safet y and Health Pr ogram which is based primarily on the r equir ements of the Hawaii Occupational Safety and Health (HIOSH) standards for the benefit and general welfare of HDOT-A em ployees HDOT-Arsquos occupational saf ety and health st ated policy is t o provide a safe accident-free and healthy wor kenvironm ent for its employees in ar eas such as

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Personal Pr otect ive Equipment (PPE)

Respiratory Pr otection

Hazardous Wast eOperat ions

Noise Exposure

Hazard Communication

Biological Agent s SARSBlood borne Pathogens

Confined Space and

Vio lence in the Wor kplac e

The Employee Health and Safet y Program is not direct ly related to air side aviation safety which is t he intent of SMS

HDOT-A does not currently have a writt en saf ety policy endorsed by Senior Exec ut ive (Top Managem ent) to indicat et heir com mitment t o aviation safet y which is a key element of an SMS

Gaps and Developmen t Required

Safety Policies

Phase 2 of theSMS project wi ll need to develop and docum ent aviation safety policies that should be endorsed by HDOT-A

Note In the developm ent of SMS som e airports have consider ed com bining SMS and employee safety in one document Initial comm ents from HDOT-A managem ent have also suggested that this integrat ion be considered However one docum ent wil l likely not be feasible or pract icable Jacobs Consultancy discussions wit h the FAA have indicated that SMS will event ually be part of the Airport Cer tification Manual (ACM) in the fut ure and that they are not interest ed or concerned with Occupational Saf ety and Health Issues or requirem ents Requirem ents by t he Hawaii Occupational and Health and by the F AA are not the sam e (for exam ple r eporting and risk analyses differ ) Although one safet y docum ent is not pr acticable we do believe that wit hin t he KOA and HDOT-A organiz ation t hose cur rently involved in safety could pot entia lly also be involved in SMS f or example a safet y of fice or off ic er that addresses both SMS and HIOSH requirem ents This organization ar rangem ent will be considered further in t he subsequent Phase 2 of this project to develop the SMS

Safety Objectives

Saf ety objectives are also requir ed to allow for assessm ent of saf ety performance and developments at the airport Safet y objectives should be linked to f actor s such as

Safety hazards identified during inspections eg type and quantity of FOD (Not e the airport rsquos self-inspect ion program captur es this infor mat ion but does not systematically monitor tr ends in this information)

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7

Airs id e safety violations

Aircr aft bird strikes

Incurs ions of vehicles aircraf tor pedest rians on movement ar eas

Ac cidents and incident s on the AOA andor the contr olled m ov ement area involving air carr ier aircraft andor ground v ehicles

Oper able time of lighting systems

Number of airs ide based employees who have received safety and SMSr elat ed t raining

Non-punitivesafet y r eports and

Airport Tower operat ing times

The safety object ives wil l need t o be inc luded in the Airport Dist rict Managerrsquos st atem ent of policy and objectives and then communicated to all of the organization They should be no diff erent f rom other organizationalobjectives in that they should be

Specific and measurable

Achiev able and challenging and

Realized within a specific t im e fram e

Mor especif ic saf ety object ivesapplicable to KOA will be d eveloped during Phase2 of the SMS pilot project

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8

III SAFETY ORGANIZATION

Key Featu res

The FAASOW f or SMS describes the follow ing requirem ent related to t hesafety organizat ion

An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel such as the following

Top Ma na gement

Saf ety Manager

Depart ment HeadsManagers

Established Saf ety Com mittees and Chairpersons

The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety The key feat ures descr ibed in the Advisory Cir cular ar eas follows

SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent) onewith t heaut hority to adequately c ontrolr esources beassigned SMSr esponsibil it ies

Defined saf ety authorities and responsibil ities f or allkey personnel that are assigned to the air port

Ident if icat ion within the system of som eoner esponsible for adm inistr ation of the overall SMS Often that one responsible person wil l be t he Safety Manager This person report s to the highest level of managem ent to assur eappr opriate consider ation of all repor ts r ecomm endations and issues

At m any air por ts oper ationsm ay support the Safety Manager being af ull-time perm anent employ ee and in som ecases having a support st aff

The responsibil ities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within theor ganizat ion

Depending on the s ize and com plex ity of the air por trsquos oper ation it may be useful to establish an Air port Safet y Committee (ASC) The safety committ ee ac ts as asource of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager

The SMS should also address how and to what extent t enants at t he airport such as the air lines fuel ing companies and ground handler s are integr ated into the airport SMS ICAO has m ade very strong ref erence to the inclusion of t enants at an airport ICAOrsquos Safet y Managem ent Manual Doc 9859 A460 Fir st Edition ndash 2006 chapter 18 ndashAER ODROME OPERATIONS statest hat

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Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

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The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

Gap Analy sis 11 KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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1 2

Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

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Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

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17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Gap An a Kona Inte rnational Airpo rt at Keahole Safety Management Sy

JT

Mor especif ical ly f or each element the Gap Analysis

1 Summ arizes the F AArsquos SMS guidance doc um entat ion internat ional guidance m ater ial where appropriate and J acobrsquos Consultancy Team rsquos SMS experience

2 Describes what systems policies and practices ex ist at KOA and then

3 Ident if ies procedures policies object ives organizational issues and document ation (ie Gaps) that need to be developed for SMS and how they will be addr essed in t he subsequent tasks to develop the SMS Manualand Saf ety Program Plan

Intent of SMS

The intent of SMS is t o im prove aviation safety The elimination of av iat ion acc idents is a desir able goal However no human activity or human-made syst em can be guar anteed t o be absolutely safe Failur es and err ors will occur in spite of best eff orts to avoid them Alt hough major air disasters are rare events less cat astrophic accident s and a whole rangeof incidents occur more fr equently Ignor ing these underlying saf ety hazar ds could pot entially pave the way for an inc rease in t he number of more serious accidents

The air transportat ion indust ryrsquos future viabilit y may well be pr ed icat ed on its ability to sust ain the publicrsquos perceived safety while traveling The m anagement of safety is therefore a pr erequisite for a sustainable aviation business

The accident rate in t he air transport industry has decreased dram atically between t he early 60rsquos and t hem id 80rsquos from 30 to near 2 per mill ion departures It could be easily argued t hat this rate was achieved f rom continuing efforts by the industry t o m akeair tr avela saf em odeof tr ansport ation But as the following diagram illustr ates bet ween the mid eighties and now we find an 80 incr ease in air tr aff ic and a 73 inc rease in the number of accidents Alt hough the accident rate per mill ion departures rem ains st eady at 2 air tr avel saf ety as perceived by thepublic is l ikely to dec line if traf fic gr owt h and accident rate per million depart ures rem ain the sam e Air t ravel relat ed accidents make instant worldwide news and there will be m ore and more reports even while maintaining a relat ively low accident rat e Safet y m anagement when well in p lace within the industry wil l be a key f actor in f urther reducing the accident r ate and achieving act ual and perceived impr ov ement in aviation s afety

7155 00

4 ly si s stem

Sou rce In tern a l Jacobs Con su ltancy for illu stra tive p u rpose s

Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

5

II SAFETY POLICIES AND OBJECTIVES

Key Featu res

The FAASOW f or SMS stat es that Safety Policies and Object ives should include

Written saf ety policy stat ement (s) and a descr iption of how it is communicat ed to airport em ployees and

Ident if icat ion and description of the air port saf ety goals

The FAA Adv isor y Circular under Saf ety Policy indic ates that managem entrsquos c ommitm ent to safety should be formally expr essed in a stat ement of safety policy t hat reflects theairpor trsquossafety philosophy and that iss igned by Top Management

Key attr ibutes of t hepolicy could also include the following

The commitm ent of senior m anagem ent to implem ent SMS

Stat es the air portrsquos intentions management princ iples and comm it ment to continuous improvement to safety at the air port

Is com municated to all employ ees

Is implemented at al l levels of the airport

Confir ms that safet y is every onersquos responsibil ity and

Recognizes that there will alway s be threats to safety and that the air port will provide the highest reasonable standard of safety The Advisory Cir cular refers to a comm it ment to make safet y t he highest priorit y which m ay have adiff erent meaning

The Adv isor y Circular under Safet y Objectives ( Section 222) does not address object ives but deals w it h the organization f or safety The Advisory Circular does r efer to safety perform ance indicat ors and tar gets under Saf ety Assurance ( Section 24)

SMS guidelines inc luding the FAA Advisory Circular g ive very l it tle practical advice on safety goals or objectives The t erms ldquogoalsrdquo and ldquoobjectives rdquo as well as ldquotargets rdquo are frequently used interchangeably The intent in the guidelines nonetheless is to have measurableindicators of safety

Existing Poli cies an d Objectives

HDOT-A has an Em ployee Safet y and Health Pr ogram which is based primarily on the r equir ements of the Hawaii Occupational Safety and Health (HIOSH) standards for the benefit and general welfare of HDOT-A em ployees HDOT-Arsquos occupational saf ety and health st ated policy is t o provide a safe accident-free and healthy wor kenvironm ent for its employees in ar eas such as

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

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Personal Pr otect ive Equipment (PPE)

Respiratory Pr otection

Hazardous Wast eOperat ions

Noise Exposure

Hazard Communication

Biological Agent s SARSBlood borne Pathogens

Confined Space and

Vio lence in the Wor kplac e

The Employee Health and Safet y Program is not direct ly related to air side aviation safety which is t he intent of SMS

HDOT-A does not currently have a writt en saf ety policy endorsed by Senior Exec ut ive (Top Managem ent) to indicat et heir com mitment t o aviation safet y which is a key element of an SMS

Gaps and Developmen t Required

Safety Policies

Phase 2 of theSMS project wi ll need to develop and docum ent aviation safety policies that should be endorsed by HDOT-A

Note In the developm ent of SMS som e airports have consider ed com bining SMS and employee safety in one document Initial comm ents from HDOT-A managem ent have also suggested that this integrat ion be considered However one docum ent wil l likely not be feasible or pract icable Jacobs Consultancy discussions wit h the FAA have indicated that SMS will event ually be part of the Airport Cer tification Manual (ACM) in the fut ure and that they are not interest ed or concerned with Occupational Saf ety and Health Issues or requirem ents Requirem ents by t he Hawaii Occupational and Health and by the F AA are not the sam e (for exam ple r eporting and risk analyses differ ) Although one safet y docum ent is not pr acticable we do believe that wit hin t he KOA and HDOT-A organiz ation t hose cur rently involved in safety could pot entia lly also be involved in SMS f or example a safet y of fice or off ic er that addresses both SMS and HIOSH requirem ents This organization ar rangem ent will be considered further in t he subsequent Phase 2 of this project to develop the SMS

Safety Objectives

Saf ety objectives are also requir ed to allow for assessm ent of saf ety performance and developments at the airport Safet y objectives should be linked to f actor s such as

Safety hazards identified during inspections eg type and quantity of FOD (Not e the airport rsquos self-inspect ion program captur es this infor mat ion but does not systematically monitor tr ends in this information)

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

7

Airs id e safety violations

Aircr aft bird strikes

Incurs ions of vehicles aircraf tor pedest rians on movement ar eas

Ac cidents and incident s on the AOA andor the contr olled m ov ement area involving air carr ier aircraft andor ground v ehicles

Oper able time of lighting systems

Number of airs ide based employees who have received safety and SMSr elat ed t raining

Non-punitivesafet y r eports and

Airport Tower operat ing times

The safety object ives wil l need t o be inc luded in the Airport Dist rict Managerrsquos st atem ent of policy and objectives and then communicated to all of the organization They should be no diff erent f rom other organizationalobjectives in that they should be

Specific and measurable

Achiev able and challenging and

Realized within a specific t im e fram e

Mor especif ic saf ety object ivesapplicable to KOA will be d eveloped during Phase2 of the SMS pilot project

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8

III SAFETY ORGANIZATION

Key Featu res

The FAASOW f or SMS describes the follow ing requirem ent related to t hesafety organizat ion

An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel such as the following

Top Ma na gement

Saf ety Manager

Depart ment HeadsManagers

Established Saf ety Com mittees and Chairpersons

The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety The key feat ures descr ibed in the Advisory Cir cular ar eas follows

SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent) onewith t heaut hority to adequately c ontrolr esources beassigned SMSr esponsibil it ies

Defined saf ety authorities and responsibil ities f or allkey personnel that are assigned to the air port

Ident if icat ion within the system of som eoner esponsible for adm inistr ation of the overall SMS Often that one responsible person wil l be t he Safety Manager This person report s to the highest level of managem ent to assur eappr opriate consider ation of all repor ts r ecomm endations and issues

At m any air por ts oper ationsm ay support the Safety Manager being af ull-time perm anent employ ee and in som ecases having a support st aff

The responsibil ities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within theor ganizat ion

Depending on the s ize and com plex ity of the air por trsquos oper ation it may be useful to establish an Air port Safet y Committee (ASC) The safety committ ee ac ts as asource of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager

The SMS should also address how and to what extent t enants at t he airport such as the air lines fuel ing companies and ground handler s are integr ated into the airport SMS ICAO has m ade very strong ref erence to the inclusion of t enants at an airport ICAOrsquos Safet y Managem ent Manual Doc 9859 A460 Fir st Edition ndash 2006 chapter 18 ndashAER ODROME OPERATIONS statest hat

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Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

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The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

Gap Analy sis 11 KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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1 2

Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

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Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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JT 7155 00

2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

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23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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JT 7155 00

2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

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a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

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Appendix B

Safety Issues

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Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

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Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sou rce In tern a l Jacobs Con su ltancy for illu stra tive p u rpose s

Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

5

II SAFETY POLICIES AND OBJECTIVES

Key Featu res

The FAASOW f or SMS stat es that Safety Policies and Object ives should include

Written saf ety policy stat ement (s) and a descr iption of how it is communicat ed to airport em ployees and

Ident if icat ion and description of the air port saf ety goals

The FAA Adv isor y Circular under Saf ety Policy indic ates that managem entrsquos c ommitm ent to safety should be formally expr essed in a stat ement of safety policy t hat reflects theairpor trsquossafety philosophy and that iss igned by Top Management

Key attr ibutes of t hepolicy could also include the following

The commitm ent of senior m anagem ent to implem ent SMS

Stat es the air portrsquos intentions management princ iples and comm it ment to continuous improvement to safety at the air port

Is com municated to all employ ees

Is implemented at al l levels of the airport

Confir ms that safet y is every onersquos responsibil ity and

Recognizes that there will alway s be threats to safety and that the air port will provide the highest reasonable standard of safety The Advisory Cir cular refers to a comm it ment to make safet y t he highest priorit y which m ay have adiff erent meaning

The Adv isor y Circular under Safet y Objectives ( Section 222) does not address object ives but deals w it h the organization f or safety The Advisory Circular does r efer to safety perform ance indicat ors and tar gets under Saf ety Assurance ( Section 24)

SMS guidelines inc luding the FAA Advisory Circular g ive very l it tle practical advice on safety goals or objectives The t erms ldquogoalsrdquo and ldquoobjectives rdquo as well as ldquotargets rdquo are frequently used interchangeably The intent in the guidelines nonetheless is to have measurableindicators of safety

Existing Poli cies an d Objectives

HDOT-A has an Em ployee Safet y and Health Pr ogram which is based primarily on the r equir ements of the Hawaii Occupational Safety and Health (HIOSH) standards for the benefit and general welfare of HDOT-A em ployees HDOT-Arsquos occupational saf ety and health st ated policy is t o provide a safe accident-free and healthy wor kenvironm ent for its employees in ar eas such as

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

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6

Personal Pr otect ive Equipment (PPE)

Respiratory Pr otection

Hazardous Wast eOperat ions

Noise Exposure

Hazard Communication

Biological Agent s SARSBlood borne Pathogens

Confined Space and

Vio lence in the Wor kplac e

The Employee Health and Safet y Program is not direct ly related to air side aviation safety which is t he intent of SMS

HDOT-A does not currently have a writt en saf ety policy endorsed by Senior Exec ut ive (Top Managem ent) to indicat et heir com mitment t o aviation safet y which is a key element of an SMS

Gaps and Developmen t Required

Safety Policies

Phase 2 of theSMS project wi ll need to develop and docum ent aviation safety policies that should be endorsed by HDOT-A

Note In the developm ent of SMS som e airports have consider ed com bining SMS and employee safety in one document Initial comm ents from HDOT-A managem ent have also suggested that this integrat ion be considered However one docum ent wil l likely not be feasible or pract icable Jacobs Consultancy discussions wit h the FAA have indicated that SMS will event ually be part of the Airport Cer tification Manual (ACM) in the fut ure and that they are not interest ed or concerned with Occupational Saf ety and Health Issues or requirem ents Requirem ents by t he Hawaii Occupational and Health and by the F AA are not the sam e (for exam ple r eporting and risk analyses differ ) Although one safet y docum ent is not pr acticable we do believe that wit hin t he KOA and HDOT-A organiz ation t hose cur rently involved in safety could pot entia lly also be involved in SMS f or example a safet y of fice or off ic er that addresses both SMS and HIOSH requirem ents This organization ar rangem ent will be considered further in t he subsequent Phase 2 of this project to develop the SMS

Safety Objectives

Saf ety objectives are also requir ed to allow for assessm ent of saf ety performance and developments at the airport Safet y objectives should be linked to f actor s such as

Safety hazards identified during inspections eg type and quantity of FOD (Not e the airport rsquos self-inspect ion program captur es this infor mat ion but does not systematically monitor tr ends in this information)

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

7

Airs id e safety violations

Aircr aft bird strikes

Incurs ions of vehicles aircraf tor pedest rians on movement ar eas

Ac cidents and incident s on the AOA andor the contr olled m ov ement area involving air carr ier aircraft andor ground v ehicles

Oper able time of lighting systems

Number of airs ide based employees who have received safety and SMSr elat ed t raining

Non-punitivesafet y r eports and

Airport Tower operat ing times

The safety object ives wil l need t o be inc luded in the Airport Dist rict Managerrsquos st atem ent of policy and objectives and then communicated to all of the organization They should be no diff erent f rom other organizationalobjectives in that they should be

Specific and measurable

Achiev able and challenging and

Realized within a specific t im e fram e

Mor especif ic saf ety object ivesapplicable to KOA will be d eveloped during Phase2 of the SMS pilot project

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

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8

III SAFETY ORGANIZATION

Key Featu res

The FAASOW f or SMS describes the follow ing requirem ent related to t hesafety organizat ion

An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel such as the following

Top Ma na gement

Saf ety Manager

Depart ment HeadsManagers

Established Saf ety Com mittees and Chairpersons

The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety The key feat ures descr ibed in the Advisory Cir cular ar eas follows

SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent) onewith t heaut hority to adequately c ontrolr esources beassigned SMSr esponsibil it ies

Defined saf ety authorities and responsibil ities f or allkey personnel that are assigned to the air port

Ident if icat ion within the system of som eoner esponsible for adm inistr ation of the overall SMS Often that one responsible person wil l be t he Safety Manager This person report s to the highest level of managem ent to assur eappr opriate consider ation of all repor ts r ecomm endations and issues

At m any air por ts oper ationsm ay support the Safety Manager being af ull-time perm anent employ ee and in som ecases having a support st aff

The responsibil ities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within theor ganizat ion

Depending on the s ize and com plex ity of the air por trsquos oper ation it may be useful to establish an Air port Safet y Committee (ASC) The safety committ ee ac ts as asource of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager

The SMS should also address how and to what extent t enants at t he airport such as the air lines fuel ing companies and ground handler s are integr ated into the airport SMS ICAO has m ade very strong ref erence to the inclusion of t enants at an airport ICAOrsquos Safet y Managem ent Manual Doc 9859 A460 Fir st Edition ndash 2006 chapter 18 ndashAER ODROME OPERATIONS statest hat

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

9

Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

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1 0

The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

Gap Analy sis 11 KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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1 2

Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

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AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

1 6

Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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JT 7155 00

2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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JT 7155 00

2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

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23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

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a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

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Appendix B

Safety Issues

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Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

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Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

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App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

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II SAFETY POLICIES AND OBJECTIVES

Key Featu res

The FAASOW f or SMS stat es that Safety Policies and Object ives should include

Written saf ety policy stat ement (s) and a descr iption of how it is communicat ed to airport em ployees and

Ident if icat ion and description of the air port saf ety goals

The FAA Adv isor y Circular under Saf ety Policy indic ates that managem entrsquos c ommitm ent to safety should be formally expr essed in a stat ement of safety policy t hat reflects theairpor trsquossafety philosophy and that iss igned by Top Management

Key attr ibutes of t hepolicy could also include the following

The commitm ent of senior m anagem ent to implem ent SMS

Stat es the air portrsquos intentions management princ iples and comm it ment to continuous improvement to safety at the air port

Is com municated to all employ ees

Is implemented at al l levels of the airport

Confir ms that safet y is every onersquos responsibil ity and

Recognizes that there will alway s be threats to safety and that the air port will provide the highest reasonable standard of safety The Advisory Cir cular refers to a comm it ment to make safet y t he highest priorit y which m ay have adiff erent meaning

The Adv isor y Circular under Safet y Objectives ( Section 222) does not address object ives but deals w it h the organization f or safety The Advisory Circular does r efer to safety perform ance indicat ors and tar gets under Saf ety Assurance ( Section 24)

SMS guidelines inc luding the FAA Advisory Circular g ive very l it tle practical advice on safety goals or objectives The t erms ldquogoalsrdquo and ldquoobjectives rdquo as well as ldquotargets rdquo are frequently used interchangeably The intent in the guidelines nonetheless is to have measurableindicators of safety

Existing Poli cies an d Objectives

HDOT-A has an Em ployee Safet y and Health Pr ogram which is based primarily on the r equir ements of the Hawaii Occupational Safety and Health (HIOSH) standards for the benefit and general welfare of HDOT-A em ployees HDOT-Arsquos occupational saf ety and health st ated policy is t o provide a safe accident-free and healthy wor kenvironm ent for its employees in ar eas such as

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

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6

Personal Pr otect ive Equipment (PPE)

Respiratory Pr otection

Hazardous Wast eOperat ions

Noise Exposure

Hazard Communication

Biological Agent s SARSBlood borne Pathogens

Confined Space and

Vio lence in the Wor kplac e

The Employee Health and Safet y Program is not direct ly related to air side aviation safety which is t he intent of SMS

HDOT-A does not currently have a writt en saf ety policy endorsed by Senior Exec ut ive (Top Managem ent) to indicat et heir com mitment t o aviation safet y which is a key element of an SMS

Gaps and Developmen t Required

Safety Policies

Phase 2 of theSMS project wi ll need to develop and docum ent aviation safety policies that should be endorsed by HDOT-A

Note In the developm ent of SMS som e airports have consider ed com bining SMS and employee safety in one document Initial comm ents from HDOT-A managem ent have also suggested that this integrat ion be considered However one docum ent wil l likely not be feasible or pract icable Jacobs Consultancy discussions wit h the FAA have indicated that SMS will event ually be part of the Airport Cer tification Manual (ACM) in the fut ure and that they are not interest ed or concerned with Occupational Saf ety and Health Issues or requirem ents Requirem ents by t he Hawaii Occupational and Health and by the F AA are not the sam e (for exam ple r eporting and risk analyses differ ) Although one safet y docum ent is not pr acticable we do believe that wit hin t he KOA and HDOT-A organiz ation t hose cur rently involved in safety could pot entia lly also be involved in SMS f or example a safet y of fice or off ic er that addresses both SMS and HIOSH requirem ents This organization ar rangem ent will be considered further in t he subsequent Phase 2 of this project to develop the SMS

Safety Objectives

Saf ety objectives are also requir ed to allow for assessm ent of saf ety performance and developments at the airport Safet y objectives should be linked to f actor s such as

Safety hazards identified during inspections eg type and quantity of FOD (Not e the airport rsquos self-inspect ion program captur es this infor mat ion but does not systematically monitor tr ends in this information)

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

7

Airs id e safety violations

Aircr aft bird strikes

Incurs ions of vehicles aircraf tor pedest rians on movement ar eas

Ac cidents and incident s on the AOA andor the contr olled m ov ement area involving air carr ier aircraft andor ground v ehicles

Oper able time of lighting systems

Number of airs ide based employees who have received safety and SMSr elat ed t raining

Non-punitivesafet y r eports and

Airport Tower operat ing times

The safety object ives wil l need t o be inc luded in the Airport Dist rict Managerrsquos st atem ent of policy and objectives and then communicated to all of the organization They should be no diff erent f rom other organizationalobjectives in that they should be

Specific and measurable

Achiev able and challenging and

Realized within a specific t im e fram e

Mor especif ic saf ety object ivesapplicable to KOA will be d eveloped during Phase2 of the SMS pilot project

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

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8

III SAFETY ORGANIZATION

Key Featu res

The FAASOW f or SMS describes the follow ing requirem ent related to t hesafety organizat ion

An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel such as the following

Top Ma na gement

Saf ety Manager

Depart ment HeadsManagers

Established Saf ety Com mittees and Chairpersons

The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety The key feat ures descr ibed in the Advisory Cir cular ar eas follows

SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent) onewith t heaut hority to adequately c ontrolr esources beassigned SMSr esponsibil it ies

Defined saf ety authorities and responsibil ities f or allkey personnel that are assigned to the air port

Ident if icat ion within the system of som eoner esponsible for adm inistr ation of the overall SMS Often that one responsible person wil l be t he Safety Manager This person report s to the highest level of managem ent to assur eappr opriate consider ation of all repor ts r ecomm endations and issues

At m any air por ts oper ationsm ay support the Safety Manager being af ull-time perm anent employ ee and in som ecases having a support st aff

The responsibil ities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within theor ganizat ion

Depending on the s ize and com plex ity of the air por trsquos oper ation it may be useful to establish an Air port Safet y Committee (ASC) The safety committ ee ac ts as asource of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager

The SMS should also address how and to what extent t enants at t he airport such as the air lines fuel ing companies and ground handler s are integr ated into the airport SMS ICAO has m ade very strong ref erence to the inclusion of t enants at an airport ICAOrsquos Safet y Managem ent Manual Doc 9859 A460 Fir st Edition ndash 2006 chapter 18 ndashAER ODROME OPERATIONS statest hat

Gap Analy sis KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

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Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

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The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

Gap Analy sis 11 KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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1 2

Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

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Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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JT 7155 00

2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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JT 7155 00

2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

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23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

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25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

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a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

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Appendix B

Safety Issues

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Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

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Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

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Personal Pr otect ive Equipment (PPE)

Respiratory Pr otection

Hazardous Wast eOperat ions

Noise Exposure

Hazard Communication

Biological Agent s SARSBlood borne Pathogens

Confined Space and

Vio lence in the Wor kplac e

The Employee Health and Safet y Program is not direct ly related to air side aviation safety which is t he intent of SMS

HDOT-A does not currently have a writt en saf ety policy endorsed by Senior Exec ut ive (Top Managem ent) to indicat et heir com mitment t o aviation safet y which is a key element of an SMS

Gaps and Developmen t Required

Safety Policies

Phase 2 of theSMS project wi ll need to develop and docum ent aviation safety policies that should be endorsed by HDOT-A

Note In the developm ent of SMS som e airports have consider ed com bining SMS and employee safety in one document Initial comm ents from HDOT-A managem ent have also suggested that this integrat ion be considered However one docum ent wil l likely not be feasible or pract icable Jacobs Consultancy discussions wit h the FAA have indicated that SMS will event ually be part of the Airport Cer tification Manual (ACM) in the fut ure and that they are not interest ed or concerned with Occupational Saf ety and Health Issues or requirem ents Requirem ents by t he Hawaii Occupational and Health and by the F AA are not the sam e (for exam ple r eporting and risk analyses differ ) Although one safet y docum ent is not pr acticable we do believe that wit hin t he KOA and HDOT-A organiz ation t hose cur rently involved in safety could pot entia lly also be involved in SMS f or example a safet y of fice or off ic er that addresses both SMS and HIOSH requirem ents This organization ar rangem ent will be considered further in t he subsequent Phase 2 of this project to develop the SMS

Safety Objectives

Saf ety objectives are also requir ed to allow for assessm ent of saf ety performance and developments at the airport Safet y objectives should be linked to f actor s such as

Safety hazards identified during inspections eg type and quantity of FOD (Not e the airport rsquos self-inspect ion program captur es this infor mat ion but does not systematically monitor tr ends in this information)

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Airs id e safety violations

Aircr aft bird strikes

Incurs ions of vehicles aircraf tor pedest rians on movement ar eas

Ac cidents and incident s on the AOA andor the contr olled m ov ement area involving air carr ier aircraft andor ground v ehicles

Oper able time of lighting systems

Number of airs ide based employees who have received safety and SMSr elat ed t raining

Non-punitivesafet y r eports and

Airport Tower operat ing times

The safety object ives wil l need t o be inc luded in the Airport Dist rict Managerrsquos st atem ent of policy and objectives and then communicated to all of the organization They should be no diff erent f rom other organizationalobjectives in that they should be

Specific and measurable

Achiev able and challenging and

Realized within a specific t im e fram e

Mor especif ic saf ety object ivesapplicable to KOA will be d eveloped during Phase2 of the SMS pilot project

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III SAFETY ORGANIZATION

Key Featu res

The FAASOW f or SMS describes the follow ing requirem ent related to t hesafety organizat ion

An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel such as the following

Top Ma na gement

Saf ety Manager

Depart ment HeadsManagers

Established Saf ety Com mittees and Chairpersons

The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety The key feat ures descr ibed in the Advisory Cir cular ar eas follows

SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent) onewith t heaut hority to adequately c ontrolr esources beassigned SMSr esponsibil it ies

Defined saf ety authorities and responsibil ities f or allkey personnel that are assigned to the air port

Ident if icat ion within the system of som eoner esponsible for adm inistr ation of the overall SMS Often that one responsible person wil l be t he Safety Manager This person report s to the highest level of managem ent to assur eappr opriate consider ation of all repor ts r ecomm endations and issues

At m any air por ts oper ationsm ay support the Safety Manager being af ull-time perm anent employ ee and in som ecases having a support st aff

The responsibil ities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within theor ganizat ion

Depending on the s ize and com plex ity of the air por trsquos oper ation it may be useful to establish an Air port Safet y Committee (ASC) The safety committ ee ac ts as asource of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager

The SMS should also address how and to what extent t enants at t he airport such as the air lines fuel ing companies and ground handler s are integr ated into the airport SMS ICAO has m ade very strong ref erence to the inclusion of t enants at an airport ICAOrsquos Safet y Managem ent Manual Doc 9859 A460 Fir st Edition ndash 2006 chapter 18 ndashAER ODROME OPERATIONS statest hat

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Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

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The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

Gap Analy sis 11 KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

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Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

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5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

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assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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JT 7155 00

2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

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23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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JT 7155 00

2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

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a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

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Appendix B

Safety Issues

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Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

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Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

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Airs id e safety violations

Aircr aft bird strikes

Incurs ions of vehicles aircraf tor pedest rians on movement ar eas

Ac cidents and incident s on the AOA andor the contr olled m ov ement area involving air carr ier aircraft andor ground v ehicles

Oper able time of lighting systems

Number of airs ide based employees who have received safety and SMSr elat ed t raining

Non-punitivesafet y r eports and

Airport Tower operat ing times

The safety object ives wil l need t o be inc luded in the Airport Dist rict Managerrsquos st atem ent of policy and objectives and then communicated to all of the organization They should be no diff erent f rom other organizationalobjectives in that they should be

Specific and measurable

Achiev able and challenging and

Realized within a specific t im e fram e

Mor especif ic saf ety object ivesapplicable to KOA will be d eveloped during Phase2 of the SMS pilot project

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8

III SAFETY ORGANIZATION

Key Featu res

The FAASOW f or SMS describes the follow ing requirem ent related to t hesafety organizat ion

An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel such as the following

Top Ma na gement

Saf ety Manager

Depart ment HeadsManagers

Established Saf ety Com mittees and Chairpersons

The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety The key feat ures descr ibed in the Advisory Cir cular ar eas follows

SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent) onewith t heaut hority to adequately c ontrolr esources beassigned SMSr esponsibil it ies

Defined saf ety authorities and responsibil ities f or allkey personnel that are assigned to the air port

Ident if icat ion within the system of som eoner esponsible for adm inistr ation of the overall SMS Often that one responsible person wil l be t he Safety Manager This person report s to the highest level of managem ent to assur eappr opriate consider ation of all repor ts r ecomm endations and issues

At m any air por ts oper ationsm ay support the Safety Manager being af ull-time perm anent employ ee and in som ecases having a support st aff

The responsibil ities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within theor ganizat ion

Depending on the s ize and com plex ity of the air por trsquos oper ation it may be useful to establish an Air port Safet y Committee (ASC) The safety committ ee ac ts as asource of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager

The SMS should also address how and to what extent t enants at t he airport such as the air lines fuel ing companies and ground handler s are integr ated into the airport SMS ICAO has m ade very strong ref erence to the inclusion of t enants at an airport ICAOrsquos Safet y Managem ent Manual Doc 9859 A460 Fir st Edition ndash 2006 chapter 18 ndashAER ODROME OPERATIONS statest hat

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Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

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The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

Gap Analy sis 11 KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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1 2

Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

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Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

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5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

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Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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JT 7155 00

2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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JT 7155 00

2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

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III SAFETY ORGANIZATION

Key Featu res

The FAASOW f or SMS describes the follow ing requirem ent related to t hesafety organizat ion

An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel such as the following

Top Ma na gement

Saf ety Manager

Depart ment HeadsManagers

Established Saf ety Com mittees and Chairpersons

The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety The key feat ures descr ibed in the Advisory Cir cular ar eas follows

SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent) onewith t heaut hority to adequately c ontrolr esources beassigned SMSr esponsibil it ies

Defined saf ety authorities and responsibil ities f or allkey personnel that are assigned to the air port

Ident if icat ion within the system of som eoner esponsible for adm inistr ation of the overall SMS Often that one responsible person wil l be t he Safety Manager This person report s to the highest level of managem ent to assur eappr opriate consider ation of all repor ts r ecomm endations and issues

At m any air por ts oper ationsm ay support the Safety Manager being af ull-time perm anent employ ee and in som ecases having a support st aff

The responsibil ities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within theor ganizat ion

Depending on the s ize and com plex ity of the air por trsquos oper ation it may be useful to establish an Air port Safet y Committee (ASC) The safety committ ee ac ts as asource of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager

The SMS should also address how and to what extent t enants at t he airport such as the air lines fuel ing companies and ground handler s are integr ated into the airport SMS ICAO has m ade very strong ref erence to the inclusion of t enants at an airport ICAOrsquos Safet y Managem ent Manual Doc 9859 A460 Fir st Edition ndash 2006 chapter 18 ndashAER ODROME OPERATIONS statest hat

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Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

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The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

Gap Analy sis 11 KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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1 2

Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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1 4

AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

1 6

Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

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17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

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25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

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a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

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13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

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Appendix B

Safety Issues

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Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

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Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

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Appendix C

Inspection Checklists

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Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Subsection 18 31

(hellip) Within the framework of an aerodrom e SMS the aerodrom e management must oversee the activit ies of all the service pr ovider s tenants contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e

Subsection 18 38

Given the complexit y of the factors cr eating risk potentialat aerodromes the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome ndash often with conflic ting expectations and pr iorities The sharing of a common focus among t hestakeholders most of whom are employ ees of agencies other t han t he aer odrome author ity needs to bef ostered In add it ion r esource commitm ents from the airlines and other ser vice providers m ust beobt ained

The FAA Circular does not addr ess t his organizat ional requir ement to any extent Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport rsquos SMS then the SMS may not be very effective Yet at the same time an airport does not have direct accountabilit y for t enant operat ions There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including

The vehicle operator perm it system

The air por trsquos self inspect ion program

Participation in Safety Comm itt ees

Safet y audits and

New and revised airport t enant use and lease agreem ents

Existing Poli cies Pr actices and Systems

The organizational str ucture for KOA is depicted in Exhibit III-1The key positions that have a direct impact on aviation safety at KOA include

The Airport sDivision Sen ior Management

The Airport District Manager

The Assistant Airport Superintendent

The Distr ict Engineer

The Gener al Construct ion and Maint enance Supervisor

The Airport Operat ions Control Supervisor

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1 0

The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

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The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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1 2

Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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1 4

AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

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1 6

Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

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17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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1 8

IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

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23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

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25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

The Airport Saf ety Security and Cert if icat ion Specia list

The Chi ef ARFF and

The Cont ract Control Tower

AIR PORT DISTRICT M AN AGER

ASSIST ANT AIR PORT SUPERINT ENDENT

DISTR ICT EN GINEER

SAFETY SECUR IT Y amp CERT IFIC ATION SPEC IAL IST

AR FF SECTION Airport F ire Commander

OPER ATIONS CONTROL SECTION

Ops Cont ro l Supervisor

M AINTENANCE SECTION

Gen eral Const ruction amp Maint enan ce

Supervisor

CONT R ACT ED CONT ROL TOW ER

AIRPORT D IVISION SENIOR M ANAGEMENT

Exhibit III-1 KOA Organizat ion Structure

The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division As well the ADM r eceives functional direct ion advice and assistance from t he Airports Division Senior Management as detailed subsequent ly The ADM m anages oper ates and m aintains KOA in conform it y with St ate and Feder al lawsand regulations as well as HDOT- Apolic ies and procedur es

The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation As such the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities m aint enanceand construction of all f acilities at K OA

The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole It is his responsibility to pr epare and prom ulgat e an em ergency plan During an emergenc y he is responsible for dir ecting act ions of the air por t emergenc y st aff providing liaison with suppor ting County State and Federal agencies and providing liaison with t he pr ess The ADM is alsoresponsible for managing GeneralLyman Field Waimea-Kohala Airport and Upolu Airport

Gap Analy sis 11 KonaInternational Airpo rt atKeaholeSafety Manage ment Sy stem JT71 5500

The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

JT 7155 00

1 2

Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

JT 7155 00

1 4

AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

1 6

Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

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17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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1 8

IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

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23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

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Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

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Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

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Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

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Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

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Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

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The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager particularly in the area of propertymanagement Healso provides management relief for the District Manager Hedoes not playa direct role in thedailyactivities of aviation safety

The District Engineer is responsible for identifying planningcoordinatingand monitoringairport maintenance projects He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering As such he is responsible for safe construction practices at KOA including theAOA

The General Construction andMaintenance Supervisor andhis staff have important responsibilities that impact aviation directly These responsibilit ies include

Maintaining the concrete and asphalt integrity of all runways taxiways and rampto provide a high level of physicalsaf ety

Daily weekly monthly and random inspections of runways and taxiways beacon and wind sock airfield lightingfencing and vegetation growth

Implementingwildlife control on the AOA if andwhen required

Maintaining runway andtaxiway paint markings to help in the prevention ofrunwayincursions

Runway rubber removal maintenance to comply with FAAStandards

Monitoringand removalof any FODon allrunwaystaxiways and ramps for prevention of accidents

Maintaining service roadway system to provide easy access aroundthe airfield without interfering with air traffic

Installation cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents

Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to providefor safe aircraft operations

Maintaining all airfield lighting for runways taxiwaysand ramps for safe aviation operations and

Maintaining emergency generator for airf ield lighting

The AirportOperationsControl Supervisor supervises the work of the Airport Operations ControlSection which consists of 5 employees (including thesupervisor) and airport policing services provided by contracted security services The Operations Control Section is responsible for

Enforcing Title IXX provisions quarterly T-Hanger inspections ensuringproper invoicing of scheduled and itinerant aircraft

Staffing and operating theAirport Operations Control Center

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1 2

Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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1 4

AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

1 6

Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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1 8

IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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JT 7155 00

2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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JT 7155 00

2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

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a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

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Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Assigning aircraft to gates when required (eg when a preferential gate is occupied as a result of delays in departures of another aircraft or earlyarrivals)

Conducting daily inspections of the runways taxiways ramps and aprons to check for FOD wildlife obstructions andother hazardous conditions

Patrols of airport operational areastomonitor and control as required the movement of aircraft vehicles and support personnel

Distributing Notice to Airmen (NOTAMs) These may be prepared by the District Airport Manager the Airport OperationsSupervisor orthe General Construction and Maintenance Supervisor

Monitoring tenant activity in T-hangars

Supervisingcontract securityservices which includes

Implementing the airport badging and vehicle identif ication program and related driver training and testing described subsequently

Perimeter patrolsand

Terminal landside andairside policing

Three of the contract security servicesrsquo officers have police powers as law enforcement officers

The Safety Security and Certif ication Specialist is responsible for participating in FAA certification inspections and ensuring correction of def iciencies He is also responsible for implementing the Employee Health and Safety Program at KOA The Safety Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations

The Airport Fire Commander directs KOArsquos Airport Rescue and Fire Fighting (ARFF) personnel and equipment He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations Based on the largest type of aircraft used at the Airport the Airport has been designated as Category D for Aircraft Rescue and Firef ighting( ARFF) The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport KOA ARFF is a 247 operation

Accordingtothe ACM ARFF is responsible for conducting inspections of fuel farmstorage and mobile fuelers KOA management expressed concerns that they did not have capability or expertise to do these inspections ARFF personnel should be trained toconduct inspections of all fueling operations on the airport The training couldbe providedunder an agreement with HCC

The Control Tower is contracted out to Air Services Pacif ic which is required to provide services in accordance with FAA regulations governing air traff ic control (ATC)

Airport Committees

There are a number of committees at KOA that deal with a wide range of tenant operations and related safety issues The committees include Gap Analy sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stem JT71 5500

13

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

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1 4

AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

1 6

Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

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17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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1 8

IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

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Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

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Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

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Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

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JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly Airport management attends this meeting Safety is discussed if it is raised as an issue by anyone on the committee

HDOT-A Employee Safety Committee that deals with occupational health and safety This committee generally meets monthlyOne of the Airportrsquos supervisor or superintendentschairsthemeeting

AGeneral Aviation ( GA) Committee that usually meets quarterly to address GAconcerns such as leases

HDOT-A Divisional Organization S tructure

The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the Stateof Hawaii The Airports Divisional organization structure is shown in Exhibit III-2The key organiz ationalunitsthat have an impact on aviation safety are as follows1

The Airport Operations Office which includes

ARFF Staff

Certification Security andSafety Staff

General Aviation Staf f

The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been s im plified to focus on sa fetyr elated organizationalunits

Gap An aly si s KonaInte rnational Airpo rt atKeahole Safety Management Sy stem

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1 4

AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

1 6

Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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1 8

IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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JT 7155 00

2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

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23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

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a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

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Appendix B

Safety Issues

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Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

AIRPORTS DIVISION

Airport Adminis trator

ARFF STAFF Airports Fire Chief

CERTIFICATION SECURITY amp

SAFETY STAFF Cert Secur ity amp Safe ty Specialist

GENERAL AVI ATION STAFF General Avia tion

Officer

AIRPORTS OPERATION OFFICE Airpor ts Opera tions Officer

ENGINEERING BRANCH Eng ineer ing Programs Manager

STAFF SERVICES BRANCH

INFORMATION TECHNOLOGY OFFICE

VISITOR INFORMATION PROGRAM OFFICE

OAHU DISTRICT

MAUI DISTRICT

HAWAII DISTRICT

KAUAI DISTRICT

ExhibitIII-2 Div isiona l Organizational Structure

Ga p Analysis 15 Ko na In te rnationa lA irpo rt at Keahole Sa fetyMan ag eme nt System JT7 15500

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

1 6

Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

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17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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1 8

IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

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25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

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13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

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Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

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Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

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Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

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C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

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D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

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D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

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D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

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Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

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Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

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App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

The Airport Operations Office provides functional direction advice and assistance to the Airport Districts and airports in Hawaii

More specifically under the direction of the Airports Operational Of ficer the ARFF Staf f for all the airports including KOA provides functional direction to the ARFF units exercises functional supervision of the Fire Commanders plans and conduct statewide ARFF training and inspects ARFF activ it ies to ensure compliance with policies and regulations

The Certification Security andSafety Section providesf unctionalguidancein airport certificationsecurity and saf ety including standardized procedures and manuals compliance inspection of related policies and procedures and administration of the divisionrsquos insurance r isk management program including accident reporting The Section to-date has primarily dealt with employee safety( eg the Employee Health and Saf ety Program Manual) The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in theDistricts

The General Aviation Section provides functional guidance related to GA facilit ies coordinates the aircraft registration process and supports GAeducationalprograms and flying saf ety programs in consultation with the FAA

The Engineering Branch is responsible for

Preparingmaster plans that need to take into account aviation saf ety issues and regulations

Managingspecial maintenance projects at all airports and

Managing capital improvement projects including construction management They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activ ities For large projects a construction management plan is developed by the contractor and reviewed and approved by the Div isional Project Manager in consultation with the District Engineer The Div isional Project Manager or the Distr ict Engineer is responsible for inspections to ensure the contractor isf ollowing the construction safetymanagement plan

Gaps and Developmen t Required

HDOT-A andKOAdo nothavean organizationalstructuredef ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS As detailed above HDOT-A and KOA do of course have managers superintendents supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations

Considering the size of KOA particularly in terms of staff members the Airport District Manager should be the senior manager responsible for SMS He has the authority to control resources within themandates set out by the Airports Division As outlined in the ACM the Airport District Manager manages operates and maintains KOA in conformity with State and Federal laws and regulationsas wellas HDOT-A po licies and procedures

At this stage of developing the SMS we recommend that the responsibilities of the Airport District Manager for SMS wouldinclude

Approvalof the SMS for KOA Gap An aly si s

Kona Inte rnational Airpo rt at Keahole Safety Management Sy stemJT 7155 00

1 6

Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

1 8

IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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JT 7155 00

2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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JT 7155 00

2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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JT 7155 00

2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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JT 7155 00

2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

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JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

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App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

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Approvalof saf ety policy andgoals

Chairing the Airport Safety Committee

Periodic reviews and updates of theSMS saf ety policy and goals for KOAand

Deployingf inancialand human resourceswithin his controlfor proper execution of the SMS

Phase 2 SMS development will needto

1 Confirm that theAirport District Manager will be responsible f or theSMS at KOA

2 Determine who at KOA willbe responsible for administering the SMS andassociated responsibilities These responsibilities include

Participating in the Airport SafetyCommittee as the Secretariat

Leading safety r isk management assessments of hazards incidents and accidents to determine action required

Conducting trend analysis of safety concerns hazards incidents and accidents and determining action required in consultation with other airport staff

Ensuring appropriate action is taken in response to safetyconcerns hazards incidents and accidents

Keepingrecords of allsaf ety related reports incidents and accidents and conducting trend analysis

Providing and coordinating safety promotion

Ensuringthe provision of safety training for airport employees and tenants located or working in the AOA

Implementing a non-punit ive reporting system

Ensuringthat safety audits are conducted when required

Measuring safety performance in relation to safety objectivesand

Annual reviewof the saf ety policy andsafety objectives

3 Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues The current Airport Operators Committee could f orm the basis of the Airport Safety Committee It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager

4 Define how tenants would be int egrated into the SMS For example part icipation in the Airport Saf ety Committeeaudits of tenant saf ety plans or programs

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17

5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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1 8

IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

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23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

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25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

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Appendix B

Safety Issues

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Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

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Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

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Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

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Appendix C

Inspection Checklists

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Appendix D

Examples of Safety and Security Enforcement Programs

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Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

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Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

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Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

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App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

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5 Determine and describethe role of the Division in SMS Our init ial views are as follows

The Airports Administrator would be responsible for

Approval of SMS safetypolicies and SMS plans f or each State airport

Periodicreviews and updates of HDOT-A SMS safetypolicies andgoals

Ensuring that f inancial and human resources requiredf or proper execution of SMS are available at airports in Hawaii and

Appointment of a SMS saf ety advisor at the Division

The SMS Safety Advisor would beresponsible for

Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazardidentification and safety risk assessment process

Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns hazards incidentsand accidents

Providingadvice to airport saf ety officerson establishingand updatingairport SMS

Developing SMS and related safetytraining material and programs thatcan be used by State airports

Monitoring implementation of the SMS at each airport

Conducting periodic audits of thesafety plans andprograms of tenants at HDOT-A airports and

Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually

6 The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as ldquooperational risk assessmentrdquo) whenever new equipment is being planned or installed or when new f acilit ies arebeingconstructedthat may have an impacton saf ety at the airport

7Determine the skills and knowledge requiredby those administering the SMS at KOA andthe Divisional SMS Advisor to ensure that personnel are capable of implementing SMS (This will likely be included in the Management Plan for implementing SMS)

In consultation with HDOT-A and KOA managers Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilit ies f or key organizational units at KOA and the Division

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1 8

IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

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19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

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23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

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25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

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13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

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Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

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Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

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Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

IV SAFETY RISK MANAGEMENT

Key Featu res

The FAASOWf or SMS describes the following requirements related to SafetyRisk Management (SRM)

Description of the saf ety r isk management process including application of ldquoThe Five Phases of SRM (saf ety risk management) rdquo as discussedin AC 1505200-37

Guidance on t heuse of SRM and trend analysis

Defined process for documenting the results of SRM including a description of how documents will be storedie electronicor paper and

Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate

The FAArsquos Advisory Circular indicates that safety risk management is a fundamental component of SMS The principal steps in the safety risk management (SRM) process include identif ication of a potential hazard analysis of theriskevaluation of the risk and development of an action plan to mitigate the risk if necessary

The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system(ie operations equipmentpeople and procedures)Possible sources of systemf ailure could include

Equipment(example construction equipment on amovement surface)

Operating environment (example co ld night lowvisibility)

Human element (example shif t work)

Operationalprocedures( examplestaff ing levels)

Maintenance procedures (example nightly movement area inspections by airport electricians) and

Externalservices( example ramp traffic by Fixed-Base Operator ( FBO) or lawenf orcement vehicles)

Existing Practi ces and Systems

KOA currentlydoes not have a formalSaf ety Risk Management processfor aviation safety

Gaps and Developmen t Required

The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project

We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management For example we will develop simple paper -based f orms for conducting a safety r isk assessment and a simplified r isk evaluation matrix for summariz ing the results of an

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

19

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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JT 7155 00

2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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JT 7155 00

2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

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Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

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JT71 550 0

assessmentThe Jacobs Team will provide training in SRM to KOA managerssuperintendent and supervisors at the end of the SMS developmentproject

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2 0

V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

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23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

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Appendix C

Inspection Checklists

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Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

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Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

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Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

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V SAFETY ASSURANCE

Key Featu res

The FAASOW f or SMS describes the following requirements related to safetyassurance

Aplan and description of employeenon-punitive reporting systems existingand planned

A description of the airport quality management andor risk management program ( if applicable) and its integration into the airport SMS

Description of a plan to integrate apron safety management into the airport SMS (The FAArsquos reviewof the plan will be limited to measures f or preventing accidents or incidents involving aircraft) The plan could include the following

a Description of current apron saf ety management practices such as reporting requirements to the National Transportation Saf ety Board (NTSB) Flight Standards or the Occupational Safety Health Administration ( OSHA)

b An explanation of how current apron safety management practices meet the intent of SMS This could include the saf ety plans and practices of tenants and operators at the airport which should complementthe airport SMS

Adetailedmethodto document self-auditingprocesses and their findings Self -auditing may be part of the airport self-inspection process If it is explain how the self -inspection process addresses systems safety ie if the self-inspection program identifies ahazard on the airport it should determine the risk anddocument the processf or follow-up

A detailed method to document self-inspection reviews analysis and findings

Process to document andreview lessons learned from within the organization

The Advisory Circular states that saf ety assurance includes self-auditing external audit ing andsafety oversight According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices

The Advisory Circular also says that in addition to the airport operatorrsquos existing responsibilit ies for self-inspection and correction of discrepancies under 14 CFR Part 139 an eff ective airport SMS audit program should

Develop identif ied saf ety performance indicators and targets (Note Jacobs Consultancy believes indicatorsand targets shouldbe addressed as part of SafetyObjectives)

Monitor adherence to saf ety policy through self-auditing

Allocate adequate resources for safety oversight

Solicit input through a non-punit ive saf ety reporting system

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21

Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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JT 7155 00

2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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JT 7155 00

2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

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JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

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Appendix C

Inspection Checklists

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Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

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Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

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JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

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Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

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Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

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Systematically review all available feedback f rom daily self -inspections assessments reports safety risk analysis and safetyaudits

Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered bythat regulation)and

Promoteintegration of a systems approach to safety into the overalloperation of theairport

The Advisory Circular also provides further guidance on non-punitive safetyreporting self-auditing and saf ety perf ormance monitoring This guidance material is provided below and generally f ollows international SMS guidancematerial

ldquoThe SMS should include a visible non-punitive safety reporting system supported by management The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns The SMS should use this information to identify and address safety deficiencies The safety reporting systemmayalso identif yand correct non-conformance to safety policyrdquo

ldquoSaf ety auditing is a core saf ety management activity Similar to financial audits safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives Senior Management may choose to have an external agency audit the system ( eg by a consultant or another airport operator) The saf ety audit together with other safety oversight activ it ies provides feedback to managersconcerningthe overall safetyperformance of the organizationrdquo

ldquoSaf ety performance monitoring validates the SMS confirming the organizationrsquos safety objectives Through regular review and evaluation management can pursue continuous improvements in saf ety management andmay revise safetyobjectives to ensure that the SMS remains eff ectiveand relevant to the organizationrsquos operationrdquo

Existing Practi ces and Systems

Airport S elf-Inspection Program

As described in the ACM Section 14 KOA has a self -inspection program in place to meet the standards detailed in AC 1505200-18 and FAR 139327 Airport Saf ety Self-Inspection Inspections by KOA and contracted securitypersonnelareconducted as follows

Daily and periodically

During and af ter construction or maintenance activity

After stormshigh winds and other majormeteorologicalevents

After earth quakes of significant magnitude and

Immediately after an incident or accident

According to the ACM as part of the self-inspection program the ARFF Section is responsible f or conducting inspections of fuel farmstorage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C) It was not clear whether ARFF also inspects handling refueling and storing of f uel FAA Advisory

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2 2

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

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2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

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JT 7155 00

2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Circular 1505200-18C page 9 ldquoAirport Self-Inspectionrdquo ref ers to daily inspection of fueling operations During the Gap Analysis there was concern expressed that the Airport did not have the capacity to conduct fueling inspections ARFF personnel should be trained to conduct inspections of all fueling operations on the airport

According to the ACM the KOA Maintenance Section conducts daily and periodic inspections of paved areas saf ety areas marking and lighting security fencing traffic and wind direction indicators and wildlif e activ ity using the form included in Appendix C of this report In addit ion the Operations Control Section including contract security services personnel conduct daily inspections of the runways taxiways ramps and aprons to check for FOD wildlifeobstructions andother hazardous conditions

Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section ARFF maintains records of f ueling inspections

Condit ions that could affect air carrier operations are disseminated to the air carriers via N OTAMS Maintenance staff init iates and records repairs as required Both the Airport Inspection Checklists and associatedwork ordersare kept on filef or12 monthsThe Inspection Checklists are included as Appendix C

Apron Safety

KOA does not havea distinct Apron Safety Program ndash aircraftmovementon the apron is not controlled

KOA does have ldquoProceduresand Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo to govern operation of vehicles These procedures andregulations address

Operations on rampand apron areas

Vehicle operations in proximity to publicaircraft

Vehicles in proximity to parked aircraft

Vehicles in proximity to movingaircraft

Accident reporting

Speed limits

Access to restricted operational areas

Fire protection

Operational saf ety area and

Fire protection

These procedures and regulations are in accordance with Hawaii Administrative Rules Title 19 Chapter 151 ldquoOperation of Motor Vehicles at Public Airportsrdquo

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

23

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

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DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

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a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

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Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

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Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

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Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified We observed that at least some of the airlinesrsquo personnel were wearing saf ety vests but that KOA and contract security services personnelwere not wearing saf ety vests Thewearing of safetyvests is astandard saf ety practice at airports domestically and internationally We recommendthat the HDOT-A consider making this requirementmandatoryf or all personnelworkingon the AOA

The ACM Section 15 refersto a range of enforcement actions available at the discretion of the Airport District Manager including an oral reprimand a written reprimandrecurrent training loss of authorization to operate on the AOA a fine and recommended t ermination of employment for State employees Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractionsviolations and specific penalties was required Reference was made to the LAX Security and Airfield Enforcement Program (SAFE) A copy is attached as Appendix D Although not necessarily part of an SMS HDOT- A should consider such an Enforcement Program

Gaps and Developmen t Required

KOA has a self-inspection program in place Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance for example trend analysis of repor ted def iciencies

Gaps that will require development in Phase 2 to meet the FAArsquos detailed guidance material referred to previously include

Non-punitive safety reporting

Systematic reviews of feedback from self-inspection assessments reports safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicatorsrelated to safety objectives

Auditingand

Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns However if it is to apply only to hazards and safety-related concerns then we question why does it need to be non-punit ive Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved Deliberate or unlawf ul actions are excluded of course This is consistent with a sy stem atic explicit and compr ehensive approach f or managing saf ety risk (AC Paragr aph 3) We have discussed thisissuewith FAA and haveconcluded that incidents and accidents should be included

The development of the non-punit ive reporting system should also consider whether tenant employeesshould be part of this systemor whether thesystem should be limited to KOAemployees We have discussed this issue with the FAA andtheyhave indicatedthat each airport is unique and should set up practices particular to their airport

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

2 4

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

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27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

VI SAFETY PROMOTION - TRAINING

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and training specifically

A plan f or employee SMS indoctrination and training SMS indoctrination training should provide an outline of proposed curriculum andresources

Documented process to identify training requirements f or systems saf ety

A plan to validate training eff ectiveness and the process to gain training feedback including useable met rics

The Advisory Circular in addition to the above states that trainingand education should include

Initial (general saf ety) job-specifictraining

Recurrent safetytraining

Training that includes human f actors andorganizational f actors and

A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training

Existing Poli cies Pr actices and Systems

The ACM refers to training for three major areas

Pedestrians and vehicles on the AOA

Inspection Techniquesand

ARFF

Pedestrians and Vehicles on the AOA

KOArsquos training material consists of a document entitled ldquoProcedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Areardquo which was described previously under Section V This document is augmented by ldquoAn FAA Guide Airport Ground Vehicle Operationsrdquo which deals with airport markings and signage and communications with the tower Although these training documents meet the intent of Part 139 it could be augmented and improved by training material especially audio-visual available from the American Association of Airport Executives ( AAAE) The training material could also be improved by using pictures of actual signage and markings at KOA We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport The latest guide is available electronically from the FAA at wwwf aagovrunwaysfetyaswdownloadsAGVO-guidedoc

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

25

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Two levels of training are provided at KOA the first level is for those who must work on aprons andramps but not on the movement areas The second level is for those who must work on the movement areas ndash primarily KOA maintenance workers After the trainee reads the applicable documentation the trainee must write and pass a written test with 80 Trainees are allowed to repeat the test until they get the correct answer and to ensurethat they understandthe basic requirements

New employees are required to pass the test before being issued a security badge This badge is valid for five years concurrent with the employeersquos State driver license KOA employees are then provided two to three weeks OJT training If the supervisor determines that the new employee hasobtained the necessaryskills the employee is permitted to drive on the AOA alone Tenants are also required to pass the basic driver training test and if necessary the more advanced test for driving on the movement areas Tenants are required to conduct their own OJT

The ACM ref ers to both initial and refresher training However only training for new employees is provided Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often

Inspection Techniques

The ACM Section 3 ldquoPersonnelrdquo ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping and AC 1505200-18BrdquoAirport Saf ety Self -Inspectionrdquo The training material that we were provided did not include this material Although KOA employees involved in this activity do not change frequently apparently contract security services personnel do HDOT-A should consider developing a training module in inspection techniques

ARFF Training

ARFF personnel according to the ACM receive instruction in accordance with AC 1505210-17 Programs for TrainingAircraf tand Fire Fighting Personnel

According to the ACM each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA The f ueling agentrsquos supervisor is required to have recurrent trainingat least once every24 months Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agentrsquos trained supervisor Written cert if ication to Airport Management is required every 12 months Records are to be maintained by ARFF

Gaps and Developmen t Required

We have provided a number of observations where exist ing Part 139 training could be improved for consideration by HDOT-A The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available

With regard to SMS given that there is no SMS in place there is a Gap in SMS requirements for SMS indoctrination and training SMS trainingwill be developed andprovided during Phase 2 of this project

Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

2 6

VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

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Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

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VII SAFETY PROMOTION - COMMUNICATIONS

Key Featu res

The FAA SOW for SMS describes the following requirements related to saf ety promotion and specifically for communications

A defined process to communicate safety policies and objectives throughout the organization including examples of howinformation willbe communicatedand any processes forfollow-up

Procedures to promote saf ety awareness and participation in non-punitive reporting systems Documented plan f or training and education saf ety communication competency and continuous improvement processes

The Advisory Circular essentiallyreiterates the requirements above but also provides someexamples including

Safet y seminars

Safety letters notices and bulletins

Safety lessons-learned

Bulletin boardssafety reporting drop boxesand electronicreporting through web sites or email

A methodto exchange saf ety-related information with other airport operators through regional offices or professionalorganizationsand

In the future voluntary posting of safety-related information on an existing FAA web-based safety reporting system currentlybeing usedby air operators

Existing Poli cies Pr actices and Systems

Although HDOT-A has a program for employee occupational health and safety it does not have a formal promotional airside safety program as envisioned under SMS HDOT-A also does not have a non-punitive reporting systemf or aviat ion safety

Gaps and Developmen t Required

Phase 2 of theSMS will develop an aviation safetypromotion program

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

27

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Appendix A

Draft Sta tement of Work

FAA SMS Airport Pilot Study

Requirements for the Final Plan

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1 OBJECTI VE

The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of aN otice of Proposed Rulemaking to incorporate SMS into 14 CFR Part 139 Cer tification of Airports

2 BENEFITS AN TICIPATED

For airport operators theapplication of a systematic proactiveand well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in thef ace of significant forecasted growth in air traff ic activity The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect andcorrect safety problems bef ore they result in an aircraft accident or incident

The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widelyvarying activity levels andoperational complexity TheFAA anticipates moving to a more formal requirement for the use of SMS at US airports consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at internationalairports Experience gained through reviewof the SMS plans developed under this pilot program willbe extremely usef ulin development of a generalUS standard

3 APPROACH

Because SMS is not a regulatory requirement in the US at this t ime the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139 (FAA would need to approve any changes to the ACM itself) FAA Airport Certification Saf ety Inspectors may ask to review the airportrsquosSMS documents but will not consider the SMS (or lack of an SMS) a factor in compliancewith Part 139

The SMS Manualand program plan should not simplyapply existingguidancethat has been developed in other countries with their own saf ety oversight rules or duplicate SMS plans of airports subject to those rules Rather the SMS Manual and plan should complement existing US saf ety requirements in 14 CFR Part 139 and be consistent with Part 139 FAA Advisory Circulars and the Airport Cert ification Manual specific to the airportrsquos current operation Therefore the SMS Manual and program plan should address which elements of the airport operatorrsquos exist ing practices and guidance materials currently meet SMS requirements which elements do not and how these practices and documents will be revised in the future for consistency with the SMS p lan

4 DELIVERABLES

The development of the SMS Manualand program should becompleted 6 months after award of the AIP grant To help FAA evaluate the SMS airport specific development process copies of the f ollowing documents must be provided to the FAA as they are completed The FAA encourages sponsors and their consultants to ref er other interim draft documents questions and comments to the FAA at anytime in the process for consultation and informat ion exchange

Gap Ana ly sis A -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

a Gap Analysis

The gap analysis should identif y procedures policies documentation and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airportrsquos ACM

Est imated completion date 2 monthsfrom project start

b Draft Plan

A draft of the complete SMS Manual and program The draft should address the gap analysis and describe saf ety risk managementr iskmitigation strategies and documentation processes

Est imated completion date 5 monthsfrom project start

c Final Plan

A copy of the finalSMSManualand program to be implemented by thesponsor

Est imated completion date 6 monthsfrom project start

The contents and scope of the SMS Manual andProgram plan shouldaddress the following

1) Written safetypolicy statement anddescription of howit is communicated to airport employees

2) Identification and description of the airport safety goals 3) A plan for employee SMS indoctrination and training SMS indoctrination training should provide an

outline of proposedcurriculum and resources 4) Documentedprocess to identif ytraining requirements for systemssafety 5) A plan to validate training eff ectiveness and the process to gain training feedback including useable

metrics 6) A defined process to communicate safety policies and objectives throughout the organization Include

examples of howinformation willbecommunicated and any processes forf ollow-up 7) A plan and description of employee non-punit ive reporting systemsexist ing and new 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel such as the

following TopManagement Safety Manager Department HeadsManagers Established Safety Committees and Chairpersons

9) Description of thesafety risk management process including application of ldquoThe FivePhasesof SRMrdquo as discussed in the FAA Advisory Circular 1505200-37 Introduction to Safety Management Systems for Airport Operators

10) Guidance on the use of SRM and trend analysis 11) Defined process for documenting the results of SRM to include a description of how documents will be

storedie electronic orpaper 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are

appropriate

A-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

13) A description of the airport qualitymanagement andor riskmanagement program (if applicable) and its integration into theAirport SMS

14) Description of a plan to integrate apron saf ety management into the Airport SMS ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft ) The plan could include a A description of current apron safety management practices already in place such as reporting

requirements to the N TSB Flight Standards or the Occupational Saf ety Health Administration (OSHA)

bAn explanation of howcurrent apron safety management practices meet the intent of SMS This could include the safety plans and practices of tenants and operators at the airport which should complement t heairport SMS

15) A detailed method to document self-auditingprocesses and their f indings Self -auditing may be part of the airport self-inspection process If it is explain how the self-inspection process addresses systems safety ie if the self-inspection program identifies a hazard on the airport it should determine the risk and document the processfor follow-up

16) A detailed method to document self-inspection reviews analysis andf indings

17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport

18) Documented plan f or training and education safety communication competency and continuous improvement processes

19) Procedures to promotesafety awareness andparticipation in non-punitivereportingsystems 20) Process to document and reviewlessons learned from within the organization 21) Schedule for implementation and anticipated associatedcosts

5 INFORMATION FURN ISHED TO THE GOVERNMENT

All documents submitted bya sponsor or its agentto the FAA for reviewunder this grant remain the property of the sponsor

Final SMS documents and plans will be considered public information Gap analyses draf t SMS manuals and plans and other interim documents may be submitted with a request for confidentiality The Freedom of Information Act requirements of 5 USC sect552as amendedwill apply to any such request

Gap Ana ly sis A -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Appendix B

Safety Issues

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Saf ety Concerns and Issues Raised during Interviews May 1 ndash 4 2008 and Correspondence Between Jacobs Consultancy KOA and other Stakeholders

During Jacobs Consultancy rsquos visits to KonaInternational Airport and correspondence with Jacobs several issues were identified that could have the potential to impact the safety of passengers airport employees or damage equipment These include

Rough Terrain Outside of the Runway Safety Areas

Ramp Congestion

Commuter Terminal Operations and

Fueling Operations

Rough Terrain Outside of the Runway Safety Areas

Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot overshoot or excursion from the runway Part 139309 requires a runway safetyarea (RSA) of 250 feeteach side of the center line of the runwayand 1000 feet at the end of the runway at KOA This RSA is to be clear of all obstacles KOA meets FAA criteria for dimensions and surface conditions

However thereis aconcern regarding the rough terrain due to the lava field on which KOA is built The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop This reduces the risks and enhances the ability for emergency response should an aircraft go beyondthe RSA KOA is unique in that it is located in the middle of a lava field The init ial construction of the airport included escalating costs due to the geology of the land to be developed Only those areas that had grading requirements were addressed

KOA has a higher risk compared with most other airports in providing emergency response to an incident should an aircraft exit or crash beyondthe RSA Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA

From a safety risk management perspective the probability of an aircraft crashing on the runway or the RSA is very remote The probability of an aircraft exiting or crashing beyond the RSA is even more remote Yet the consequences could be catastrophic KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areasoutside of the RSA should be graded to remove obstacles Due to the expected high capital coststhis study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis The actual r isk should be based on historical accident and incident records of aircraft crashing on or ending up outside the RSA The study should also consider the number times that aircraft at KOA use the 17-35 runway duringcross wind conditions due to the lack of a cross-wind runway Accident and incident reports are available from the FAA and world wide sources The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be The results of the analysis should be usedto set priorities for any corrective action in comparison with other capital works at KOA

Gap Ana ly sis B-1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Ramp Congestion

KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller Due to the growing local economy and tourist activities KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan The size of aircraft has also increasedwith US flagcarriers usingaircraft as large as B-767rsquos and B-757rsquos andJapan Airlines flyinga B-777 The conf iguration of the airport terminalbuildingsand ramphas lead to congestion as KOAhas accommodated the air carriers

Activity on the rampcan be intense with largenumbers of groundservice vehicles 10000 gallon f uelingtrucks and airline vehicles and employees perf orming airline operations Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t Passengers must use hard standsasjet bridges are currently not available

Saf ety concerns identifiedinclude

Push back Theramp is an uncontrolled movement area Departingaircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway Aircraft power-in when arriving Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp It has been suggested that lines be painted to show where aircraft should be parked This way the carrier couldposition their ground equipment to service the aircraf t Konas problem is that in painting the box KOA would have to have the box for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions

Equipment operating near and around surrounding aircraft have the potential of striking other aircraft equipmentemployees and passengers in these tight spaces

Lack of markedvehicle lanes does notdirect themovement of ground vehicles potentiallycausing damage or injury

Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp This has the potential of causing accidents and injuries Some of equipment ownershave not properly cleaned the spills or repaired the equipment causing on going spills Bradley who provides fuel for the air carriers does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills

Commuter Terminal Operations

Commuter Airlines have been movedto a temporary terminal This terminal andramp is located in an area that includes cargo operations helicopter tour and flight school operations and fueling operations The temporary terminalis planned to be replaced in the near futureto betterhandle passengers and air line tenants

Saf ety issues identif ied in this area include

Inadequateramp lighting in thecommuter terminal area that may lead to damage to aircraft or vehicles or injury to passengers and employees There was a recent accident in this area where a commuter aircraft struck alight polewhile attempting to maneuver in this constrained area

The f ueling operations are located near the commuter operations The movement of aircraft fuel trucks andpassengers in this confined area andthelack of lighting is apotentialhazard

B-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Tour helicopter operations and flight school operations are located adjacent to the commuter ramp Several indiv iduals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area Concerns included the flight path used and skill level of the new pilots using the adjacent ramp and

During the holiday season generalaviat ion increases and all available parkingis used to handle the number of aircraft including Taxiway B This adds congestion to the activities already being conducted in this part of the airportDOTAhas identified an area for GA expansion to assist in reducing this r isk

Fueling Operations

KOA has a lack of fuel storagecapacity both on and near the airport There is a small fuel farm locatedon the airport that includes a self serve Av Gas tank This has lead to tankertrucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA Fixed Based Operators (FBOrsquos) use 10000 gallon fueling trucks to help off set the capacity shortage The FBOrsquos do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously

Saf ety issues identif ied include

The large vehicles add to the congestion on the ramp Theymust maneuver around aircraft other ground vehicles air linepersonneland passengers

With the constant transf er of f uel there is concern that the fuel does not have the opportunity to sett le long enough causing a potentialfor catastrophic events and

As mentioned above the aircraft ref ueling vehicles must be maintained on the ramp This has lead to oil leaks causing the potentialf or safetyrelatedissues

Gap Ana ly sis B-3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Appendix C

Inspection Checklists

Gap Ana ly sis KonaInternational Airpo rt at KeaholeSafety Manage ment Sy stemJT71 5500

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Gap Ana ly sis C -1 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

C-2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Gap Ana ly sis C -3 KonaInternational Airpo rt at KeaholeSafety Manage ment Sy ste mJT71 5500

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

C-4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem

JT 7155 00

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Appendix D

Examples of Safety and Security Enforcement Programs

Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

D-2 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

D-4 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

D-6 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

D-8 Gap Analy sis K ona Inte rnational Ai rp o rta t Keahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Generic Safety Enforcement Program

Saf ety is t he first r esponsibility of all airs ide driver sat At no t im e do operational considerat ion such as t im e pressures al low driver s to disobey this Airside SOP

The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privilegesor have the AVOP holder c omplete additional tr aining andor testing result ing fr om a violat ion (or violat ions) of this Airside SOP

Ther eare four m ain objectives of t he Demer it Point System

1 To reinfor ce the importance of safe airside driv ing 2 To have a fair pred ictable and transparent method for reinf orcem ent 3 To create a system f or progr essive discip line for repeat off enders and 4 To have the r ight t o r evoke an AVOP f rom unsafe driver

Demerit Point Sy stem

Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System

The Airport Safety SectionAirport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets

All air sid e driver s will c omm ence with zer o (0) points Points will ac cumulate based on the inf ract ion a driver com mits Pr evious r ecordspoints will remain on file ndash as st ated in the violat ion chart Mult iple violations at the same time will r esult in m ult iple point s

AVOP Suspensionr evocat ion

6 point accumulat ion = 5 working day suspension

10 point acc umulat ion = 10 working day suspension

14 point acc umulat ion = 20 working day suspension

18 point accumulation = AVOP r evocat ion

Gap Analy sis D-9 Kon aIn ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

Char t of Violations

VVii oollaattii oonn OOffffee nnccee ((ss eeccttiioonn ampamp bbrrii eeff ddeessccrriippttiioonn )) PPeennaallttyy

Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Char t of Violations

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Class A Failing to give r igh t o f-way to pedestrians

Refus ing to s ubmit a br eath alyzer

12 poin t

Danger ous dr iving Driving gre ater than Record6 years Driving u nder t he 25 kmh r above

influence of speed limit

alcoholdr ugs

Class B Failing t ogive r ight-of- Failing t ooperat e a 6 point way to aircraft or veh icle safely at all res ponding emer gency times veh icle Driving wit hout a

Care less driving valid air port licens e Record 4years Driving betwe en Driving wit hout a

aircr aft and mars haller valid Governme nt Failing t oc omply with Driver s Licens e

AVOP enforcement Driving 1 5 to 25 per sonne l kmhr a bove speed

Smoking airside limit

Runwa y inc ursion

Class C Failing t ouse vehicle Par king in 2 point s corridor unauthor ized

Failing t oe nter par king loca tion

appr oximating a 90 Using a pers onal degr ee angle radio while dr iving Record2 years

Failing t oobey a stop airside sign Driving 1-14k mhr

Failing t oyie ld to traffic above speed limit

within ma in vehicle corridor

Towing more tha n4 car ts dollies

Failing t or epor t an acc ide nt

Class D Violation ofdirectives not c over ed in t he above T obe deter mined classes

D-1 0 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

Sp eed Limits

N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or where no speed lim it is posted 50 kmh (30 mph)

The m aximum speed limits are

10 kmh (6 mph) within 6 m (20f t) of aircr aft or in congest ed areas and on the Head of Stand Road

25 kmh (15 mph) on all apron areas vehicle corr idors (not including Head of Stand Road) and airside roads

50 kmh (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol)

Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations

N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons aircraft vehicles or equipment having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to bet hereon

Gap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0

App eal Pr ocess

13 0 Ve hic le Oper ati ng Pr ocedure

1st Level Appea l

A let ter de tailing t he infraction t he points allott ed andthe t otal points accumulate d to dat e will be forwar ded to the AVOP hold and hisher employer Within seve n(7) days ofthe iss uance of this le tte r ana ppeal ma y be ma de in the form of a letter includinga de script ion of the circums tances and justificat ion of appeal The appeal le tter must be forwar ded to Safet y Office where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired Ar guments citing oper ational neces sity will not be considered as a nappeal A decision regarding the appea l will be s ent tot he AVOP holde r wit hin 7 days oft he date of the appe al notific ation

2nd Level Appea l

stIf the AVOP holder disagr ees with the r esult s ofthe 1 appeal a na ppeal ma y be made by lette r tothe Airport Director within 15 days ofth e decision The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOPholder may bring an agent to ass ist int he present ation of the appe al T he decision oft he Dir ector is final andc onclusive

Poi nt AccumulationInterviews

The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es

To act upon a pote ntially da ngero us situation To re infor ce the element of safe air side driving at th e a ir port To impres s upon the indivi dual the ser iousness ofbad driving habits To educate t he employee on acce ptable dr iving ha bit s

The Airpor t Safety Officer may de em it necessary to have an AVOPholder re-tes ted

Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits

A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op Do not drive between a marshaller their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor operators may proc eed

No pe rson shall opera te a vehicle within 15 m (50 ft) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate dvehicle c orr idor

A vehicle operat or shall ensure the vehicle he she is dr iving is in s ound mechanica l condition A mal function shall be r epor ted to your supervisor however t he vehicle oper ator is r esponsible for the vehicleequipment hes he is operat ing on airs ide

D-1 2 Gap Analy sis K onaInte rnational Ai rp o rta tKeahole Safety Manage ment Sy stem

JT71 550 0